U.S. Transnational Income Tax Rules & the Probable Reform in the Sourcing of Corporate Income Earned Abroad

Main Article Content

Stephen Utz

Abstract

In today’s global economy, tax formalism must be tempered, if not altogether abandoned. Thus, the replacement of Subpart F of the Internal revenue Code with a régime of greater flexibility in the attribution of corporate income to a U.S. source seems inevitable. This article explores that possibility and tries to anticipate some of the details of the reform in the light of current U.S. fiscal problems.

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How to Cite
Utz, S. (2014). U.S. Transnational Income Tax Rules & the Probable Reform in the Sourcing of Corporate Income Earned Abroad. AU-GSB E-JOURNAL, 2(2). Retrieved from http://www.assumptionjournal.au.edu/index.php/AU-GSB/article/view/396
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Articles
Author Biography

Stephen Utz

Professor Stephen Utz teaches at the University of
Connecticut School of Law, Hartford, U.S.A.