TY - JOUR
AU - Shay, Stephen E.
AB - Jerusalem Review of Legal Studies, Vol. 9, No. 1 (2014), pp. 104–115 doi:10.1093/jrls/jlt037 Published Advance Access February 6, 2014 Theory, Complications, and Policy: Daniel Shaviro’s Fixing U.S. International Taxation Stephen E. Shay* Introduction Daniel Shaviro’s Fixing U.S. International Taxation ties together his previous critiques of U.S. international tax policy toward outbound foreign direct invest- ment (FDI) in an illuminating and engagingly written book. Shaviro’s primary objective is to improve the quality and scope of the U.S. international tax policy discussion by applying welfare economics analysis to re-examine stalemated issues in U.S. taxation of FDI. Fixing International moves beyond critique of policy and offers a range of policy alternatives to respond to these issues. The book is a valuable addition to the literature on U.S. international taxation for tax scholars and policy makers. Shaviro identifies the principal moving pieces in the international tax puzzle as five ‘‘building blocks’’ of U.S. outbound international tax rules: the rules for corporate residence, source of income (gross and net), foreign tax credits, deferral of U.S. tax on income of foreign corporations and exceptions to de- ferral for controlled foreign corporations (CFCs) (known as the Subpart F rules). He argues that the current system of 
TI - Theory, Complications, and Policy: Daniel Shaviros Fixing U.S. International Taxation
JF - Jerusalem Review of Legal Studies
DO - 10.1093/jrls/jlt037
DA - 2014-06-05
UR - https://www.deepdyve.com/lp/oxford-university-press/theory-complications-and-policy-daniel-shaviros-fixing-u-s-jhm13gydBQ
SP - 104
EP - 115
VL - 9
IS - 1
DP - DeepDyve
ER -