Despite all my frivolous posts in recent days on such burning issues as adolescent Triceratops, the supposed U.N. plot against Colorado, and possibly bombastic indie rockers, I actually am reasonably hard at work writing on international tax issues.
My foreign tax credit paper is pretty much final for two publications (long version in the Journal of Legal Analysis, short version in the National Tax Journal), and I am also working with an economist co-author on a follow-up piece with empirical content. More on this in due course.
My main project these days is a piece entitled "The Rising Tax-Electivity of U.S. Corporate Residence," projected to be my Tillinghast Lecture at NYU Law School next month (on Tuesday, September 21) and then an article in the Tax Law Review. I will talk some about what we can tell about the trend described (or rather asserted) in the title, and somewhat more about how it should affect our thinking about international tax issues. I'm reasonably pleased with it so far, as I was with the foreign tax credit paper (and this is not a constant I experience equally with all of my papers), based on a feeling in both cases that the item ought to be (whether or not it actually proves to be) intellectually influential.
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