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President Barack Obama last week personally introduced a set of proposals to reform U.S. international taxation that are the most significant advance toward preserving the income tax on cross-border transactions since the enactment of the subpart F rules by the Kennedy administration in 1962. (For prior coverage, see Doc 2009-10047 or 2009 TNT 84-1.) In essence, the Obama proposals introduce a 21stcentury version of the vision begun by Thomas Adams in 1918 and continued by Stanley Surrey in 1961: a world in which source and residence taxation are coordinated so as to achieve the underlying goals of the international tax regime. As I have explained at length elsewhere, those goals are known as the single tax principle (all income from cross-border transactions should be subject to tax once, not more and not less) and the benefits principle (active income should be taxed primarily at source, and passive income primarily at residence).


Reprinted with the permission of Tax Analysts.