International tax rules, which determine how countries tax cross-border investment, are increasingly important with the rise of globalisation, but the modern US rules are widely recognised as dysfunctional. The existing debate is stuck in a sterile dialectic, in which ostensibly the only permissible choices are worldwide or residence-based taxation of US companies with the allowance of foreign tax credits, versus outright exemption of the companies' foreign source income. In this book, Shaviro explains why neither of these solutions addresses the fundamental problem at hand.

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