Authors:

  • Stephen E. Shay

Excerpt

Defending Worldwide Taxation with a Shareholder-Based Definition of Corporate Residence. Stephen Shay, March 5, 2017, Paper, "This Article argues that a principled, efficient, and practical definition of corporate residence is necessary even if some form of corporate integration is adopted, and that such a definition is a key element in designing either a real worldwide or a territorial income tax system as well as a potential restraint on the inversion phenomenon. The Article proposes that the United States adopt a shareholder-based definition of corporate residence that is structured as follows:..." Link