Slicing the Shadow: A Proposal for Updating U.S. International Taxation

Authors

Reuven S. Avi-Yonah, University of Michigan Law SchoolFollow

Document Type

Article

Publication Date

6-2012

Abstract

In the article Avi-Yonah proposed that the United States tax multinational corporations using a formulary apportionment system based solely on income derived from sales. The background for the article was drawn principally from Robert Reich’s The Work of Nations (1991), and the analysis was inspired by Stanley I. Langbein’s work on transfer pricing, especially his seminal article "The Unitary Method and the Myth of Arm’s Length," Tax Notes, Feb. 17, 1986, p. 625; see also Louis Kauder, "Intercompany Pricing and Section 482: A Proposal to Shift From Uncontrolled Comparables to Formulary Apportionment Now," Tax Notes, Jan. 25, 1993, p. 485.

Comments

Reprinted with the permission of Tax Analysts.

Recommended Citation

Avi-Yonah, Reuven S. "Slicing the Shadow: A Proposal for Updating U.S. International Taxation." Tax Notes 135, no. 10 (2012): 1229-34. (Originally published under the same title in Tax Notes 58 (1993): 1511)