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Editor: Paul L. Caron, Dean
Pepperdine University School of Law

Friday, February 15, 2013

Oldani: Rehabilitating the U.S. Corporate Income Tax System

Jessica L. Oldani (Attorney, Chicago), Rehabilitating the U.S. Corporate Income Tax System in Light of Current Realities and 26 U.S.C. Section 965, 46 Int'l Law. 709 (2012):

The U.S. corporate income tax system is outdated, overly prescriptive, and too complex and oppressive to respond efficiently and effectively to global business. As highlighted by § 965, the international provisions are especially stale. Yet, multinational enterprise income dominates the business environment, and cross border transactions are on the rise. I recommend placing global business concepts and the international tax code provisions at the center of restructured rules that include the following: new entity definitions and transaction/source rules that reflect evolving business realities; a strengthened worldwide system capable of encompassing border-defying income activity; principles-based standards to remain dynamic and relevant, as well as to simplify the Internal Revenue Code and Treasury Regulations and to clarify congressional intent; ending deferral for U.S. foreign-source income; reducing the overall corporate income tax rate; and integrating the corporate and individual income tax systems according to the Comprehensive Business Income Tax prototype put forth by the U.S. Treasury Department.

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