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| Stephen Shay
Two Cheers for the Foreign Tax Credit, Even in the BEPS Era. Stephen Shay, November November 2016, Paper, "Reform of the U.S. international income taxation system has been a hotly debated topic for many years. The principal competing alternatives are a territorial or exemption system and a worldwide system. For reasons summarized in this Article, we favor worldwide taxation if it is real worldwide taxation; that is, a non-deferred U.S. tax is…