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1 Kyle Pomerleau & Kari Jahnsen, Designing a Territorial Tax System: A Review of OECD Systems 1 (2017)

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FISCAL
FACT
No. 554
Jul. 2017


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    August  16th Update: Additional information on each  country's profit
    shifting rules has been added to the body of the text and the appendix.



 Designing a


 Territorial Tax System:


A Review of OECD Systems


Kyle Pomerleau              Kari Jahnsen
Director of Federal Projects Research Assistant



Key Findings

   *  A central goal of corporate tax reform is to fix the U.S.'s system for taxing the
      foreign profits of domestic businesses.

   *  Many  lawmakers  have sought to reform the corporate tax by moving
      to a territorial tax system, which would exempt foreign profits of U.S.
      multinational businesses from domestic taxation.

   *  Over the past 30 years, the vast majority of America's largest trading partners
      have moved  to territorial tax systems.

   *  The territorial tax systems throughout the 35 member nations of the
      Organisation for Economic Cooperation  and Development   (OECD) vary
      substantially in scope and design.

   *  All OECD  countries with territorial tax systems have designed provisions that
      seek to prevent base erosion and profit shifting by multinational corporations.

   *  Designing a territorial tax system requires balancing competing goals:
      completely exempting  foreign business activity from domestic taxation,
      protecting the domestic corporate tax base, and a simple system. A system
      can generally only choose up to two of these.

   *  Moving  to a territorial tax system would improve the U.S. corporate tax
      system. However,  corporate taxation is inherently complex and lawmakers
      will need to carefully consider how to structure a territorial tax system for the
      United States.


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