Title: Taxing Foreign Corporations on U.S. Business Income
Abstract:This proposal recommends that engaging in business in the United States should be determined on the basis of the regularity of transactions both inside and outside the United States; that the source a...This proposal recommends that engaging in business in the United States should be determined on the basis of the regularity of transactions both inside and outside the United States; that the source and doing business rules take into account a U.S. audience or customers; and that financial investments involving credit be treated as interest. Gain from derivative contracts would continue to be exempt (with exceptions): Gain from portfolio stock by foreigners would also be exempt without regard to technicalities, but gain from takeovers of U.S. businesses would become taxable. This regime is intended to affect tax-haven investors rather than those who obtain treaty protection.The proposal is made as a part of the Shelf Project, a collaboration by tax professionals to develop and perfect proposals to help Congress when it needs to raise revenue. Shelf Project proposals are intended to raise revenue, defend the tax base, follow the money, and improve the rationality and efficiency of the tax system. Shelf Project proposals follow the format of a congressional tax committee report in explaining current law, what is wrong with it, and how to fix it.Read More
Publication Year: 2008
Publication Date: 2008-03-10
Language: en
Type: article
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