Authors:

  • Stephen E. Shay

Excerpt

Designing a 21st Century Corporate Tax -- An Advance U.S. Minimum Tax on Foreign Income and Other Measures to Protect the Base. Stephen Shay, July 31, 2015, Paper. "The 21st Century has seen unprecedented levels of corporate tax aggressiveness and avoidance. This article continues our exploration of second best international tax reforms that would protect the U.S. corporate tax base and have some likelihood of adoption. In this case, we consider how a U.S. minimum tax on foreign income earned by a controlled foreign corporation should be designed to protect the United States against erosion of its corporate income tax base and to combat tax competition by low-tax intermediary countries. In the authors’ view, a minimum tax should be an interim levy that preserves the residual U.S. tax on foreign income, as distinguished from a final minimum tax that partially eliminates the U.S. residual tax ...." Link