Tuesday, November 18, 2014

You take what you can get

Harry Grubert has published a thoughtful review of my book, Fixing U.S. International Taxation, in the latest issue of the National Tax Journal.  It's a good read, not just for anything it says about my book, but perhaps even more so for its addressing some topics (such as formulary apportionment) that I mention in the book, but that have been been of especial long-term interest to him.

Although Harry is an economist and I'm a lawyer, he might actually have preferred a more "lawyer"-type book, whereas I wrote a conceptually more "economist"-type one.  Thus, take what I consider to be an important conceptual advance from the book and my related prior articles: distinguishing between (a) the tax burden on outbound investment and (b) the incentive to minimize foreign taxes.  To me, this is inherently important, in the sense that it relates to clear thinking.

Harry agrees that I have advanced the ball on thinking about U.S. companies' incentives with respect to foreign taxes, and that this may be "particularly useful" to keep in mind as the international tax reform process goes forward.  But he notes that there are also plenty of other important issues in international taxation relating to lots of margins.  Some might even have greater practical importance than this one.  (As I would agree.)

Harry's focus is thus, in a sense, more practically grounded than mine - as it should be, given how much he knows about the empirical interrelationships, across decades, of multiple moving pieces.  But there is certainly room for both types of approaches.  I very much look forward to our further exchanges on international tax topics.

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