Fixing U.S. International Taxation

Daniel N. Shaviro is the Wayne Perry Professor of Taxation at New York University School of Law. Prof. Shaviro's scholarly work examines tax policy, budget policy, and entitlements issues. Before entering teaching of law, he spent three years in private practice at Caplin & Drysdale, a leading tax specialty firm, and three years as Legislation Attorney at the Joint Congressional Committee on Taxation, where he worked extensively on the Tax Reform Act of 1986. Books he has published include: Decoding the U.S. Corporate Tax (2009); Taxes, Spending, and the U.S. Government's March Towards Bankruptcy (2007); Who Should Pay for Medicare? (2004); Making Sense of Social Security Reform (2000); When Rules Change: An Economic and Political Analysis of Transition Relief and Retroactivity (2000); and Do Deficits Matter? (1997). He holds an AB summa cum laude from Princeton University and a JD from Yale Law School.

• Acknowledgments ; 1. Introduction and Overview ; Part One: The Rules and Their Main Effects ; 2. The Main Building Blocks of U.S. International Taxation ; 3. Planning and Policy Issues Under the Existing U.S. Rules ; Part Two: Developing and Applying a Policy Framework ; 4. The Global Welfare Perspective ; 5. The Unilateral National Welfare Perspective ; 6 What Is To Be Done? ; Bibliography ; Index

"Through Fixing U.S. International Taxation, Daniel Shaviro has undertaken a thorough reconceptualization of the United States' approach to international tax law and policy. Shaviro proposes a complete reformulation in the hope of reshaping the treatment of foreign taxes and the determination of tax rates on foreign source income." -Jim Chen, Jurisdynamics"The true value comes from Shaviro's proposals and ideas. The subject matter is unavoidably complex, but he strives to boil down the material to the stuff that helps us achieve the task assigned in the title of the book. His explanations are clearly developed and rational so that readers with only a minimal background in international tax can follow even the most difficult issues. Unlike so much that is written on international tax, there is no ostensible pro-or anti-business slant and no political bias If you are striving for a true understanding of the issues involved in this historic transformation, you are lucky Shaviro wrote this book when he did."-Martin A. Sullivan, Tax Notes