International Taxation


Incidence and efficiency of capital taxes in open economies


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international

Incidence and efficiency of capital taxes in open economies.

  • Distinguishing taxes on saving from taxes on investment.
  • What are the effects of source-based taxation of investment income in open economies? How open must the economy be in order to apply the analysis of small open economies?
  • Residence v. source basis for taxing business and personal income.
  • Who bears the burden of source-based and residence-based taxation in open economies?

Evidence of behavioral responses to international taxation

  • Effects of taxation on the magnitude and location of foreign direct investment.
  • Effects of taxation on various forms of tax avoidance. Effectiveness of anti-avoidance rules.
  • Effects of taxation on factor prices.
  • Are FDI and tax avoidance likely to become even more responsive to tax differences in the future?

Tax reform proposals in open economies

  • Which reform proposals fare best in open economy environments? Consumption v. income taxation. How much of a concern is revenue erosion through avoidance?
  • What are the effects of tax asymmetries in open economies? For example:
    • Favorable treatment of startup firms.
    • Treatment of tax losses.
    • Subsidies for R&D.
    • Transaction-based taxes such as capital gains taxes and stamp duties.

International choices embedded in the UK tax system

  • What aspects of the post-1977 evolution of UK taxes are attributable to international pressures?
    • Statutory tax rates
    • Abolition of the ACT
    • Treatment of R&D
    • Double tax relief
  • What costs and tradeoffs are implicit in various international features of the tax system?

The tax treatment of foreign income

  • The UK taxes on a worldwide basis, allowing foreign tax credits.
  • Taxation largely on the basis of repatriation, with foreign tax credit limits.
    • Restrictions on cross-crediting.
    • Controlled foreign corporation regime.
  • What are the costs are associated with this system? What would be the revenue implications of major reform?

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