Integration in an Integrating World

42 Pages Posted: 22 Feb 2005

See all articles by Yariv Brauner

Yariv Brauner

University of Florida Levin College of Law

Date Written: February 2005

Abstract

During the second half of the last century many countries gradually replaced their so-called classical corporate tax regimes, under which corporate earnings were taxed twice - once in the hands of the corporation, and again when distributed to corporate shareholders as dividends - with an integrated regime (imputation), which taxed such earnings only once. The driving force behind this trend was the expectation of significant efficiency gains. This clear and gradual trend has been abruptly reversed with the turn of the century. The phenomenon we call globalization, and in particular the proliferation of cross-border business and investment, has materially contributed to this dramatic sea change in the corporate tax world. The conventional wisdom was that imputation is unsustainable in a world whose markets integrate. This article argues that the abandonment of imputation is partly a consequence of our essentially non-cooperative world in terms of tax policy coordination. It concludes that imputation does not have to be the victim of globalization - it can be retained to the benefit of many countries, but only through enhanced international cooperation and coordination of tax policies.

Keywords: Corporate Tax, Dividend Taxation, Imputation

JEL Classification: K34

Suggested Citation

Brauner, Yariv, Integration in an Integrating World (February 2005). Available at SSRN: https://ssrn.com/abstract=670441 or http://dx.doi.org/10.2139/ssrn.670441

Yariv Brauner (Contact Author)

University of Florida Levin College of Law ( email )

P.O. Box 117625
Gainesville, FL 32611-7625
United States
3522730949 (Phone)

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