Fleming Presents Formulary Apportionment in the U.S. at McGill

J. Clifton Fleming (BYU) presented Formulary Apportionment in the U.S. International Income Tax System: Putting Lipstick on a Pig? (with Robert J. Peroni (Texas)) yesterday at McGill as part of its 4th Annual Tax Policy Colloquium hosted by Allison Christians:

[T]he authors argue that formulary apportionment and the current standard, arm's length transfer pricing, are just two shades of lipstick on the pig that is the US international tax system, with its twin features of deferral and cross-crediting. They conclude that formulary apportionment might be the less offensive shade, but in effect the whole discussion is a diversion from a broad reform that is sorely needed on the pig itself.