The passage of the American Taxpayer Relief Act of 2012 (ATRA) offers an opportune moment to consider proposals for corporate and international tax reform. With the debate over individual tax rates for the income and estate tax settled for the present, the President and Congress are free to consider broader reforms. Few observers doubt that such reforms are sorely needed, for several reasons. First, the long-term budgetary outlook is unsustainable. Second, the U.S. corporate tax rate is the highest in the Organisation for Economic Co-Operation and Development (OECD). Third, the current system raises relatively little revenue and large amounts of corporate income go untaxed. Finally, the system is horrendously convoluted and imposes high transaction costs. This Article will attempt to raise some proposals for U.S. corporate and international tax reform, beginning with long-term options (a ten year horizon), continuing with the medium-term (two to five years), and concluding with short-term options (one to two years).
Avi-Yonah, Reuven S. "Corporate and International Tax Reform: Proposals for the Second Obama Administration (and Beyond)." Pepp. L. Rev. 40, no. 5 (2013): 1364-72.