And another article

I've just finished a first draft of my new article, "The Rising Tax-Electivity of U.S. Corporate Residence," though I probably won't post it on SSRN until after I deliver it at NYU on September 21 as the Tillinghast Lecture. Some good stuff in it, including (a) what we know about such electivity today, (b) state of the play on the distributional (pertaining to individuals) as well as efficiency issues raised by residence-based entity-level worldwide taxation, and (c) a proposed $200 billion (!) transition tax if the U.S. shifts from its current sort-of-worldwide system to a territorial one. (This number, at this point, is back-of-the-envelope at best, but I think it's reasonably in the ballpark.)

Once I've put this article to bed for the time being, I'll return to my (suspended since late 2009) book in progress, Fixing the U.S. International Tax Rules.