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