Oops, interrupting my international tax book again, this time to prepare slides for my talk in Chicago next week (Nov. 19) at the National Tax Association's 103rd Annual Conference on Taxation, where I will be on a panel discussion (with Donald Marples, Jane Gravelle, Ed Kleinbard, and Lee Sheppard) entitled "International Corporate Taxation: Are We Headed in the Right Direction"?
I'm enthusiastic about how my slides (which I will as usual post on the NYU Law website and this blog) are shaping up. They will distill the basic conclusions I am reaching in the book-in-progress, which are a bit novel except for their general foreshadowing in a few of my recent international tax articles on SSRN.
Hint # 1: I will trash all of the worldwide welfare norms (such as capital export neutrality or CEN, capital import neutrality or CIN, and capital ownership neutrality or CON) that dominate so much of the expert discussion. Death to alphabet soup & the battle of the acronyms.
Hint # 2: My bottom line will conditionally endorse a shift from our current supposedly worldwide tax to a territorial system, but I would expect U.S. multinationals greatly to prefer present law to what I suggest.