Inversions, Related Party Expenditures, and Source Taxation: Changing the Paradigm for the Taxation of Foreign and Foreign-Owned Businesses

Authors

Julie A. Roin

Abstract

The disconnect between the rules for the taxation of domestic businesses and foreign and foreign-owned businesses operating in the United States both diminishes the federal treasury and distorts taxpayer and business behavior. Yet bringing the sets of rules into closer coordination is no simple task. This Article examines many of the solutions proffered in the academic literature and details the difficulties and trade-offs that each entails.

Rights

© 2016 Brigham Young University Law Review

Recommended Citation

Julie A. Roin, Inversions, Related Party Expenditures, and Source Taxation: Changing the Paradigm for the Taxation of Foreign and Foreign-Owned Businesses, 2016 BYU L. Rev. 1837 (2017).
Available at: https://digitalcommons.law.byu.edu/lawreview/vol2016/iss6/9