Part I of this note will examine the structure of the FSC, and analyze its potential benefits in light of the Domestic International Sales Corporation (DISC) tax incentive. Part II discusses the use of the unitary tax as a disincentive to direct foreign investment by U.S. corporations. Finally, Part III outlines the new export policy based upon a combination of the FSC export incentive and state unitary taxation of foreign-source income. If implemented, this policy would increase export production and discourage direct foreign investment, thereby making a substantial contribution to U.S. economic well-being.
Reed D. Rubinstein,
A New Export Policy: The Foreign Sales Corporation and State Unitary Taxation of Foreign Source Income,
Mich. J. Int'l L.
Available at: https://repository.law.umich.edu/mjil/vol6/iss1/5