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52 IRET Policy Bulletin 1 (1991)

handle is hein.taxfoundation/iretpbul0011 and id is 1 raw text is: June 28, 1991
_No. 52
COMPETITIVENESS AND THE U.S. TAXATION OF
CORPORATE INCOME
The current House Ways and Means Committee hearings on the issue of U.S. competitiveness
indicate the beginning of serious Congressional concern over the effect on the U.S. position in the
world economy of a cumulation of tax and other legislation adopted with strictly domestic political
considerations in mind. From the tax standpoint, the failure to consider competitiveness had its
culmination in the 1986 tax legislation, when the rules applying to business, and to international
operations in particular, were wrung out to produce revenue to fund personal tax cuts, leaving in the
aftermath a system that many regard as essentially unadministrable and economically damaging.
The hearings announcement makes it clear that a fundamental reexamination of principle is invited.
This is all the more welcome for being long overdue.
It is a str-iking fact that the U.S. approach to the taxation of inter-national
business oper-ations is unique in the world in important respects.. .this
uniqueness alone should sound war-ning bells. What do other- nations know
that we may have been missing?
We must begin to come to terms with the overriding fact of cross border economic integration.
Today U.S. firms' overseas sales exceed $1 trillion, or four times U.S. exports. Exports and imports
account for nearly a fifth of our economy, about double the proportion of only two decades ago. (In
some European countries, exports and imports are over 40% of the economy.) An increasing portion
of exports and imports consist of materials, work in process, and capital goods, rather than finished
products. Major industries now operate across national boundaries in the way they operate across
state borders. (Imagine the condition of our economy if each state imposed a tax regime similar to
our federal rules!)
It is a striking fact that the U.S. approach to the taxation of international business operations is
unique in the world in important respects, particularly regarding its impact on activities taking place
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