Fixing U.S. International Taxation provides a major rethinking of the tax issues raised by cross-border investment and the activities of multinational corporations.

Discusses two fundamental principles of US taxation of international transactions, i.e. tax jurisdiction and the source of income rules. Explains how the US taxes the foreign activities of domestic corporations, US citizens and other US persons. Includes chapters on the foreign tax credit, the deemed paid foreign tax credit, transfer pricing, controlled foreign corporations, foreign sales corporations and income tax treaties. Describes how the US taxes the US activities of foreign corporations, non-resident alien individuals, and other foreign persons.

Explains why perfecting, rather than curbing, interstate competition would make international taxation both more efficient and more just.

This report describes and assesses the principal prescriptions that have been offered for broad reform of the international system. It begins with an overview of current law and possible revisions. It then sets the framework for considering economic efficiency as well as tax shelter activities. Finally, it reviews alternative approaches to revision in light of those issues.