A Hitchhiker's Guide to Outbound International Tax Reform

  title={A Hitchhiker's Guide to Outbound International Tax Reform},
  author={J. Clifton Fleming and Robert J. Peroni},
In this article, we argue that although some U.S. international income tax reforms, such as limitations on earnings stripping, can be handled by targeted legislative action, broad reform of the U.S. international income tax system should take place only as part of a general revision of the U.S. corporate income tax. We further argue that U.S. international income tax reform should not lose revenue, should take fairness issues into account, and should discount the competitiveness and complexity… CONTINUE READING


Publications referenced by this paper.

The allocation of domestic expenses to foreign-source exempt income must be accomplished in a more realistic and appropriate way than the inadequate 5-percent “haircut

Fleming, Peroni, Shay
  • Id. at 431–35
  • 2014