publication . Article . 2002

The David R. Tillinghast Lecture - What's Source Got to Do with it - Source Rules and U.S. International Taxation

Shay, Stephen E.; Fleming, J. Clifton, Jr.; Peroni, Robet J.;
Open Access English
  • Published: 01 Jan 2002
  • Publisher: New York University
  • Country: United States
Abstract
Arguably, the largest problem in international income taxation is the proper treatment of income that is subject to the legitimate taxing claims of two or more countries. A source country's jurisdiction to tax foreign persons is limited to income earned within the source country's borders. Under current international norms, however, the taxpayer's residence country is required to accommodate the source country's taxing right by employing a foreign tax credit or by exempting foreign source income. Thus, source taxation is at once geographically constrained, but also jurisdictionally superior to residence taxation. These principles require that international incom...
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