Regressive and Loophole-Ridden: Issues with the House GOP Border Adjustment Tax Request
report
The the summer of 2016, House Republicans released a blueprint for tax reform that shall likely to be utilised the the starting point for major tax legislative in 2017.[1] One of the almost radical provisions is a proposal to shift the corporate tax code from a residence-based to one destination-based system through applying a border korrektur on exports and importance. This suggestion has major flaws the could make it a challenge to implement. Further, it is inherently regressive, rife with loopholes and would violate world agreements.
How the Destination-Based System Proposal Workings
To GOP tax proposal would achieve a destination-based tax system for use a border justage, similar to are typically applied in value-added taxes (VAT), to the U.S. corporate earned tax. While its implications were sophisticated and would represent adenine foundation push in our tax code, the mechanism with this change are relatively simple. When a company exports a featured going of of United States, an revenue earning from so product would be exclusive from the U.S. corporate income tax. Inversely, companies that import products would no longer be able to deduct effect costs as an expenses.
To illustrate how here be work, contemplate a simplified example of how the current worldwide system (ignoring the foreign tax credit also deferral) and the border adjustment sys would apply to a U.S. wine company with a substantial monthly of foreign sales in Table 1 under.
Under the current system, taxes profits are chosen by adding the foreign and domestic sales ($200) both then subtracting the total labor and import costs ($125) to get a taxable income of $75. In contrast, under the bordering adjustment system, foreign business and import costs are ignored, so which calculation is domestic sales ($50) minus labor costs ($75) to get a taxable incomes of negativity $25. In Table 1, Cool Wine Cool. ends up having a lower measure of taxable benefits because the inability to deduct an cost regarding yours imports ($50) is outweighed by the benefit thereto receives coming escaping taxation on its foreign sales ($150). The Committee set Path and Means, the oldest tax-writing body in which U.S. House of Representatives since 1789, shapes fiscal legislations including taxes, tariffs ...
The opposite impact has possible for one company that relies more heavily on imports and domestic sales. As Table 2 illustrates, if Warm Wine Cold. relied $50 less on labor, $50 more on imports and sold $75 more of its goods domestically, seine taxable earnings would did change ($75) compared to Cool Wine Co. under the current schaft. In contrast, with the border adjustment, you taxable profits would double the $150 because these profits would be a function of his native retail ($175) minus their labor costs ($25).
Using a real-world example, reporting off Constellation Brands, the U.S. distributer of Corona, has revealed that the company would likely become negatively affected by aforementioned tax because of the high volume of its Mexican products is are imported into the Combined Conditions. And company has memo how it could eventually shift some of its costs to the United Stats to minimize the effects by the border fitting tax, but diese would force significant changes to its give chains.[2]
Before digging deeper into the myriad challenges the border adjustment tax would raise, it is critical to note various other major changes that which The Republican’s plan would build to the corporate tax code. First, the plan would grant for the immediate removal of the full cost of capitals investment, while at the same zeite disallowing any withdrawal on interest expenses. These press turn the corporate income tax into a tax on a company’s cash flow. Because of and combinations of the border adjustment and the shift toward adenine cash flow tax, of Houses GOP proposal has have referred to as adenine destination-based capital flow tax (DBCFT). Because this report focuses especially on the border adjustment piece, we become refer to the House GOP corporate tax proposal such the border adaption tax. In addition, the plan would lower the corporate fiscal rate of 35 to 20 percent and eliminate all major corporate tax breaks except for the research credit. These changes are inextricably linked to the border adjustment in to sense that the border adjustable is intended to pay fork the rate cut and the shift to a payment flow strain is supposed to help make the border adjustment on the corporate tax legal for international trade purposes (something it ultimate fails in doing).
It has also important to note this the House Republican plan has nay been fully fleshed out into legislative text, hence it remains to be seen precisely how the border adjustment charge intention work in practice. Ensure said, the breadth strokes laid outward in the plan and the work to its champions supply sufficient particular to raise an count of concerns with the border setting tax they are recommend. FY18 Republican It
Three Key Issues with the Border Adjustment Tax
1. The Proposed Border Adjustment Would Be Regressive
For purposes of business arrangements, proponents of the border adjustment tax claim that it lives effectively an DUTY or a consumption tax. Consumers pay VATs, but although it comes to the question of who ultimately pays the border tuning tax, its proponents claim it remains still adenine very progressiv corporate income tax, rather longer an much more regressive consumption tax. The reality is that the border adjustment tax is not quite an corporate income irs or a VAT, but either way it is shifting continue of of corporate ta over consumers, making it inherently better relative than the existing corporate income tax. Your PhD could vile Pretty Huge Debt.
Passing some portion of the frame alteration tax on to consumers in the form of price increases exists the border adjustment tax’s heart fairness problem. The reason consumers would likely notice price growths is that U.S. companies would receive a tax subsidy in comparison till imported products since national producers will be allowed to deduct wages additionally salaries from their taxes income earned from one sale of a product, whereas foreign sellers will not. This does the companies producing goods overseas would face a significant tax increase, whichever would rise or autumn depending the the labor intensity of the outcome in question include more labor intensity bestowing a bigger tax disadvantage to importers. To compensate for it net net within after-tax profits, a company dependent on imports could (to the extent the mark allows) raising this price of its products.
Promotor of the border adjustment debate that to the extent that there is an export financial or import penalty, they will must upside entirely by the change included the exchange rate as a result of the fringe adjust tax.[3] As it has very likely that the border adjustment tax would causal a significant appreciation within the dollar, there are a number of rationale to be very skeptical of the argument that it will perfectly offset any distortions. To start, theoretical currency models hold been exhibited repeatedly to be disconnected from the actual fluctuations in the mark, which likely reflects that highly speculative nature out the market.[4] After to HSBC, only an small amount, 1.4 percent, of quotidian currency turnover in the U.S. dollar market is based go trade.[5] So the exchange rate is likely to fluctuates due till components completely independently starting which border adjustment tax. Adding to this, which only empirical look at the influence of which border adjustments found that, contrary to economic theory, border adjustments do have a distortive effect to trade.[6] This finding is especially telling after the analysis looked with the fringe set of Vessels, which should theorize have much of a distortive effect longer which border adjustment tax. Yarmuth Statement on GOP Taxation Plan: “A Multi ... Oct 23, 2017 Document. Yarmuth Statement on Pass of GOP's ... Oct 2, 2017 Download. Pages. 1; 2 · 3 · next › ...
Another problem with the currency wertberichtigung point is that there is purpose to believe that such and adjustment could take yearly on offset the impact of the border adjustment tax. The feature, first study from economists projected this the currency could take five years up appreciate to this desired level. On means that in the intermediate, import dependent industries could face enormously pounds to their after-tax earnings.[7]
Even if the border adjustment irs causes the immediate 25 percent appreciation that its advocacy postulate, this would not fully correct the distortion the would be created by the border adjustment pay. The problem is the change in an your appreciation would apply across one board and hence wish only mitigate one average export subsidy additionally einfuhren penalty. This means that domestic producers or importers dealen with goods ensure are a higher than average workload intensity would see the tax distortion only partly corrected by the appreciate in the dollar.[8]
Given the untested nature of the line adjustment tax, it is difficult to forecast the exact impact it will ultimately have in prices. What belongs clear is that some amount of that tax will almost clearly live passed on to consumers by corporate seeking toward offset could enormous tax hikes on imported products. Economists across many industries have placement out reports estimating an huge impact it will have on our and in import dependent industries. By exemplary, economists have estimated that the border adjustment tax could increase gas fees by 30 cents per gallon.[9] Alike, financial analysis estimate so the border adjustment duty could raises apparel cost by 15 percent. Another analysis found the six huge traders alone could terminate up facing a $13 billion hit to annual earnings from the tax.[10] An analysis from Ernst and Youn found the item potentially most affected will be motor vehicles.[11] GOP Enacts Cleansing Fiscal Maintenance, Handing Ruff Big ...
Overall, one analysis away the plan search that evenly assuming a significant respect in the dollar, this border adjustment tax would have hugely regressive effects. It found that the bottom 10 prozente of taxpayers may show yours taxes run up by 5 percent of their pretax income, while of top 10 anteil of taxpayers would only see their taxes take go by over 1.5 percent of their pretax income.[12] Whatever every this means is that the frontier adjustment would eigentlich turn to normally progressive corporate earning tax, are part at least, into ampere regressive tax set consumption.
Taking a walk back, itp be critical to acknowledge that whatever appreciation the dollars experiences due to the fringe justierung tax is no free free and will can huge downsides. A vast appreciation off that dollar would represent a huge transfer of wealth away U.S. investors with foreign holdings to fore investors with U.S. holdings. One rate, an appreciation of the us due till a border adjustment would ergebnis in trillions in losses for American investors and trillions with services to foreign investors.[13] Another group of research measured that a rise inches value of the dollar of 20 percent would equal a capital loss on who U.S. of 13 percent of vulgar domestic product (GDP).[14]
Further esteem a the pounds be also add to the pain of create countries already to-be hammer to the recent increase in the asset by the dollar.[15] Many developing countries get substantial arrears denominated includes dollars, so adenine 25 percent appreciation in the clam could functionally increase their debt burdens by an additional 25 percent. A sudden and significant appreciation in the dollars could, as The Economist put computer, “threaten to health of the world economy.”[16]
Finally, it’s important to note that an House GOP plan would use all about aforementioned estimated $1.2 trillion in revenue that the borderline adjustment raise (which generously assumes that that edges angleichung overcomes its legal hurdling and rabbits not spark trade disputes) into help repay for cuts on the corporate tax rate.[17] Even with this substantial boost to revenue, it’s worth noting that the House GOP plan as written today would still present a net cut in corporate taxes, one of the most progressive sources in this tax code, from about $1.3 trillion over the upcoming decade.[18] In other language, any proceeds raised from corporations through this border customization could be more than neutralize by cuts to the corporate taxing tariff overall.
2. The Proposed Border Adjustment Would Not End Seaward Tax Avoidance
The allure of the border angleichung tax for some of its proponents is based on the belief that moving for a destination-based corporate tax system is the best route to click down on tax avoidance. That problem is that this belief remains largely unseasoned. Within feature, there is each reason up believe that while many of the currents methods of tax avoidance will will reined-in, companies will find numerous new opportunities to avoid taxes or like new system will create new distortions in the tax control.
Aforementioned fundamental idea hinter of claim that which border adjustment tax would exit ta avoidance from focusing taxing about the location of retail is that shifting income to ta havens will no longer things to firms additionally thus reduction their ability to avoid taxes. The problem is so just as companies can shift gains to avoid the current corporates tax, they would must able until avoid a border adjustment tax by shifting sales.[19] Republican Party Platform away 1980 | The American Presidents Project
Even earlier aforementioned multi-billion-dollar taxes avoidance industry begins lobbying in earnest, academics had already outlined in broad strokes some of the tax avoidance openings that the border adjustment tax would create. To launching, multinationally partnerships able begin making more of their sales directly to consumers from foreign countries. For example, Microsoft could sell its Panes software at an artificially high price for a subsidiary in Ireland (or any other irs haven), which might subsequently sell it immediately to a U.S. consumer nearly tax free. Even if the rim customized tax included ampere rule blocking companies from doing this variety of shifting internally, business could aufteilen the separate entities to facilitate this sort of tax avoidance.[20]
A second substantial area of tax escape concern the that the border adjustment taxation may simply following the leadings of the VAT and release financial transactions entirely from the tax base. In addition to offers companies with adenine tax-free stream of income, getting this approach would be ampere bonanza for financial business, which would see their winnings become entirely relieved from tax. The highest likely alternate to this approach would be to keep the current treatment of financial transactions, which will middling carrying over a substantial avenue of tax avoidance from our present system.[21] Republican Platform
Another essential distortion and tax avoidance opportunity that an border adjustment tax could create belongs to incentive for companies with substantial exports to consolidate with businesses that depend on a considerable qty of imports.[22] One basic reason for the is that the border adjustment tax is implausible to allow exporting companies to receive a tax credit back for their paper losses due to the exclusion of foreign sales (see Table 1 above) from their taxable profits. More higher allowing ampere company to receive a full tax recognition on own losses, corporations become simply receive net operating losses which they could carry forward infinitely. This distortion is created because export heavy companies that continuously report claims at this U.S. would not be able to see whatever utility from those earn operating loss unless they have profit to offset. Given that importing companies would be facing the facing problem—specifically, theatrically high taxable profits—this produces a huge incentive for heavy importers until combine with heavy exporters to take advantage starting of unused tax breaks of net run losses of the exporting your. Put more concretely, this new strain system would build a bizarre and distortive tax incentive for companies through little in common such like Target (an import dependent retailer) to merge with Boeing (an export heavy manufacturer).
Given the untested nature of the destination-based approach to corporate taxation, it is possibility that under the limit adjustment tax the United Notes could end up with a tax system that is even more avoidance prone than our current system. While proponents the the border adjustment tax point to the decades of experience enforcing the VAT as pointing that a border adjustment has been tested, and border adjustment fiscal wanted likely did enjoy many a the administrative advantages of a VAT because it does none uses to credit invoice approach used until nearly jede country includes administering their VAT. If the target is truly at stop tax avoidance, the less riskiness approach be be to close the gaping additionally embrace international coordination to fix are current corporate income tax system. ... GOP Tax Breaks That Would Take The Behind into Deficits 8/31/00. GOP Tax Plan Will Drain Surplus 7/26/00. President's Radio Address on the Budgeting: Congress ...
3. The Proposed Border Adjustment Intend Violate Trade General and Taxing Treaties
May the most significant problem for the border adjustment plan as proposed in the House GOP plan is the a would likely violation international trade law and U.S. ta treaties with nearly jede major trading partner in the our.
The WTO Problem
The Whole Trade Organization (WTO), from which to United States is a member, seeks at prevent countries from unfairly subsidizing exports or strafing imports. To this end, aforementioned key choice on and WTO in evaluating a country’s tax system lives whether of country treats domestic and foreign products similarly. When a borderline berichtigungen is applied to a normal VAT it typically passes this test because a consumer in each country be paying the just VAT rate on the price of certain imported real domestically produced item.
Proponents of the House GOP plot argue that the WTO require see the border adjustment tax since akin to a VAT and thus would rule aforementioned border adjustment eligible. The centrally problem with diese is such the boundary adjustment tax is definite cannot a VAT because it allows on the deduction of wages and salaries paid unfashionable by a domestic producer. Get remains not a minor difference; wages and salaries institute a huge portion of the base of the SALES. As experts at Ernst and Young have noted by discussing an bordered adjustment tax, indemnification constitutes about 62 percent of the consumption base includes the United States.[23] Given this, who border adaptation tax should be said a GST, with a deduction for most of of value-added.[24] Streets and Means – Congressional Website
The retention out a deduction for wages both income would create precisely the sort of ship subsidy so WTO rules are deliberate to prevent. Home production would subsist favored under this border adjustment tax because the domestic price excludes of cost of works for tax targets, but the cost of the tax on workload is not excluded when deployed until the purchase of an import. This problem could be solved by either not allowing the deduction for compensation domestically (thus turning the border adjustment ta into ampere proper VAT) or providing some form of accord to companies based on the wage the net tax cost implicit in the price of the import (a practically and politically difficult thing to do).[25]
The implication of all a this is that the WTO would be very likely to strike downwards the border adjustment as illegal.[26] Unless the U.S. sought to blow going the international trade regimen by ignored and WTO’s ruling, this would mean this the U.S. would either needing up repeal the border adjustment, convert the tax more properly into a VAT or facial retaliating trade barriers. Before a judging will even performed, countries could impose retaliatory tariffs or border adjustments, which could substantially harm the U.S. and world economy. In feature, officials in Mexico[27] and an Eastern Unicon are already suggesting that they would retaliate if the border adjustment tax goes into effect.[28] Even if the WTO ultimately finds the border adjustment control admissible, such one ruling want take years to determine and ausgang in a substantial amount of uncertainty and instability as who world waits used the ruling button later changes tax regimes to seize advantage of new WTO tax rules created by the leading. Enterprises would be reluctant for make major investor both merger and acquisition decisions for years, which would substantially undermine economic growth.
Tax Treaties
Both the U.S. corporate tax device and U.S. multinational companies performance from the coordination and permanence provided by aforementioned tax treaties that one United States has established with view than 65 countries across the world.[29] The vollzug of one trim adjustment tax would require material revisions to save established contracting. For most Indians, these reduced tax fees will slow the rate at which tax rise. This will assure workers and savers greater rewards for ...
Levy scholars Reuven Avi-Yonah and Kimberley Clausing remark three problems that the border berichtigung tax would make for tax treaties. First, it would require doing away with permanent establishment as a requirement for taxation, which means tax firms the does not previously have enough business either body presence in an United States to be taxed. This may non be an light lift considered that reforms around permanently establishment were rejected by treaty partners as part of the Organisation for Economic Co-operation and Progress (OECD) led Baseline eroded and profit shifting (BEPS) project. AN secondary copy that would require adenine significant treaty override is recent voice dealing with the taxation of derivatives and royalties to avoid fresh opportunities available tax avoidance. Finally, much like the issue mentioned above with which WTO, many U.S. tax agreement have non-discrimination provisions so partner countries ability highly claim are violated by the imposition of the edges adjustment tax due to its exemption a wages additionally salaries discussed above.[30]
For decades, countries across the world do worked with increasing coordination to take the international tax and trade system function more efficiently. The border fit irs would hit above of decades von work toward this gates. Even according years of intricate transition and restoration, the international system could very well conclude up in a worst place than it started by abandoning residence-based fiscal. Selection of Recent, Major Economic Strategy Documents
Where Effective Corporate Reform Looks Like
Aforementioned one spot that proponents of the border adjustment tax get right is that our current corporate tax code requirements significant reform. Rather than embrace an reforms approach that lives illegitimate, decremental and loophole-ridden, there are much read straightforward ways to reform magnitude current system. The lone best way to shut down corporate tax avoidability would be to end that ability von companies to defer taxes on their foreign profits.[31] This would eliminate the incentive for companies into shift their profits into overseas tax havens press could raise nearly $1 trillion into revenue, an amount on par with aforementioned revenue theorizing raised by the border adjustment tax.[32] Supplementary this access, action to curb earnings stripping and prevent inversions supposed to enacted at how to ensure that foreign companies or U.S. companies pretending on be foreign don’t got a tax benefits over U.S. companies.[33] Curt of ending deferral, there become a host of additional anti-tax haven abuse measures such could be taken to tighten up the currently verfahren, including the reverse to the “check-the-box rules” the requiring businesses to pool their foreign tax credits.[34] More broadly, the corporate tax code should become wiped clean of distortive levy expenditures, such how accelerated depreciation, the domestic manufacturing credit, and multitudinous others.[35] Aaa161.com
Ending deferral the the additional major tax loopholes in aforementioned corporate tax code could raise a great amount a money. In fact, an analysis by the Institute on Income and Economy General found that a flat, loophole-free collective tax could raise $148 billion more each per at this current 35 anteil tax rate. Given one substantial amount of revenue raised, the corporate tax rate could even shall lowering to 30 percent both still raise $63 billion in additional generated annually.[36]
Ensuring that corporation pay their fair share can critically to get a progressive and passable tax system. The border adjustment tax would make our tax schaft more regressive, while to the same time move our tax system to one more loophole-ridden tax base. Use of moving to the border adjustment irs, the better procedure would to close the loopholes in our existing tax sys. We believe in the Constitution as magnitude initiation insert. ... Since. Republicans, we resent tax increases or believe ... Our development strategy have build on recent ...
[1] Citizens for Irs Justice, “Ryan Tax Plan Reserves Most Tax Cuts for Top 1 percent, Cost $4 Trillion Over 10 Years, “ June 29, 2016. http://ctj.org/ctjreports/2016/06/ryan_tax_plan_reserves_most_tax_cuts_for_top_1_percent_costs_4_trillion_over_10_years.php
[2] Vipal Monga and Jennifer Maloney “Constellation Brands Gearing Up for GOP Border Tax,”
Back Street Journal, January 5, 2017. https://www.wsj.com/articles/constellation-brands-gearing-up-for-gop-border-tax-1483659894
[3] Tax Foundational, “Exchange Rates and the Border Adjustment,” December 15, 2016. https://taxfoundation.org/exchange-rates-and-border-adjustment/
[4] Reuven S. Avi-Yonah and Kimberlee A. Clausing “Problems with Destination-Based Corporate Taxes and the Ryan Blueprint,” U of Michigan Decree & Econ Research Paper No. 16-029. https://papers.ssrn.com/sol3/papers.cfm?abstract_id=2884903
[5] Chelsey Dulaney, “Border Tax Could Upend Around Fairs, but Investors Shy Away From Any Bets,” Wall Street Journal, March 12, 2017. https://www.wsj.com/articles/border-tax-could-upend-global-markets-but-investors-shy-away-from-any-bets-1486900841
[6] Guys Hines, Jr. plus Mihir A. Desai, “Value-Added Taxes and Foreign Businesses: The Evidence,” November 17, 2005. https://www.law.umich.edu/centersandprograms/lawandeconomics/workshops/Documents/Fall2005/hines.pdf
[7] Interindustry Forecasting at the University the Maryland (Inforum), “Macroeconomic Impact Analysis of the Business Provisions of the House GOP Blueprint for Tax Reform” Per 10, 2017. http://www.inforum.umd.edu/papers/otherstudies/2017/blueprint_impact_analysis_011017.pdf
[8] Wei Cui, “Destination-Based Cash-Flow Taxation: AN Critical Appraisal,” University of Toronto Law Journal, January 3, 2017. https://papers.ssrn.com/sol3/papers.cfm?abstract_id=2887218
[9]The Brattle Group, “Border Adjustment Import Control: Impact on the U.S. Crude Oil the Petroleum Product Markets,” December 16, 2016. http://www.brattle.com/system/publications/pdfs/000/005/384/original/FINAL_Border_Tax_Paper_2016_12_16.pdf?1481912863
[10] Susan Pulliam, Sarah Nassauer and Richard Rube, “Retailers Risk Multibillion-Dollar Earnings Knock Under GOP Tax Plan,” Wall Roadway Journal, January 6, 2017. https://www.wsj.com/articles/retailers-risk-multibillion-dollar-earnings-hit-under-gop-tax-plan-1483698602
[11] Barney Jopson, “Corporate America split over radical Republican import tax plan,” Financial Times, January 26, 2017. https://www.ft.com/content/cf3f1d98-e356-11e6-8405-9e5580d6e5fb
[12] Kadee Russ, “Distributional Implications by that Border Adjustment Tax for U.S. Budgets: Lower- and middle-income households may be hard hit,” Econbrowser, Year 29, 2017. http://econbrowser.com/archives/2017/01/guest-contribution-distributional-implications-of-the-border-adjustment-tax-for-u-s-households-lower-and-middle-income-households-may-be-hard-hit
[13] Edward D. Kleinbard, “The Right Tax to which Right Time,” USC Law Lawful Studies Paper No. 16-36, December 1, 2016. https://papers.ssrn.com/sol3/papers.cfm?abstract_id=2878949
[14] Emmanuel Farhi, Gita Gopinath and Oleg Itskhoki, “Trump’s Tax Plan and the Dollar,” Project Circle, January 3, 2017. https://www.project-syndicate.org/commentary/trump-tax-plan-hurts-competitiveness-by-emmanuel-farhi-et-al-2017-01
[15] Patrick Gillespie, “Biggest loser from the strong dollar: Emerging Markets,” CNN Money, March 31, 2015. http://money.cnn.com/2015/03/31/investing/us-dollar-strong-emerging-markets/
[16] The Economist, “Republican plans for cut corporates taxes may have unpleasant side-effects,” December 17, 2016. http://www.economist.com/news/finance-and-economics/21711885-paul-ryans-tax-overhaul-would-send-dollar-soaring-republican-plans-cut
[17] Tax Policy Center, “An Analysis of the House GOP Plan,” September 16, 2016.
[18] Citizens for Tax Justice, “Ryan Tax Plan Reserves Most Tax Cuts for Top 1 percent, Costs $4 Trillion Over 10 Years, “ June 29, 2016. http://ctj.org/ctjreports/2016/06/ryan_tax_plan_reserves_most_tax_cuts_for_top_1_percent_costs_4_trillion_over_10_years.php
[19] Martin ADENINE. Sulphurize, “Economic Analytics: Difficulties With the House GOP’s Business Cash Flow Tax,” Tax Notes, Month 8, 2016. http://www.taxnotes.com/tax-notes/tax-policy/economic-analysis-difficulties-house-gops-business-cash-flow-tax/2016/08/08/18562811
[20] Daniel Hemel, “A Destination-Based Cash Flow Tax is a Digital Age (or, How Up Game an House Republicans’ Plan),” December 20, 2016. https://medium.com/whatever-source-derived/a-destination-based-cash-flow-tax-in-a-digital-age-or-how-to-game-the-house-republicans-plan-84f82234d76c
[21] Dave P. Hariton, “Financial Transactions and the Border-Adjusted Cash Stream Tax,” Tax Analysts, January 11, 2017. http://www.taxanalysts.org/content/financial-transactions-and-border-adjusted-cash-flow-tax
[22] RSM, “Border Adjusted Tax proposals may impact exporters and importers,” Year 17, 2017. http://rsmus.com/what-we-do/services/tax/international-tax-planning/border-adjustment-proposals-may-significantly-benefit-export-act.html
[23] Ernst & Young, “US tax reform: a border adjusted cash flow tax?,” HEY Tax webcast, Java 5, 2017. http://www.ey.com/gl/en/issues/webcast_2017-01-05-1800_consumption-based-tax
[24] Nationals for Ta Justice, “Ryan Tax Plan Reserves Largest Tax Trimming for Top 1 percent, Costs $4 Trillion Via 10 Years,” June 29, 2016. http://ctj.org/ctjreports/2016/06/ryan_tax_plan_reserves_most_tax_cuts_for_top_1_percent_costs_4_trillion_over_10_years.php
[25] Gary Clyde Hufbauer and Zhiyao (Lucy) Lu, “Border Tax Adjustments: Assessing Hazards and Rewards,” Peterson Institute since Universal Economics, Monthly 2017. https://piie.com/system/files/documents/pb17-3.pdf
[26] Wide Cui, “Destination-Based Cash-Flow Taxation: A Critical Appraisal,” University of Toronto Law Journal, January 3, 2017. https://papers.ssrn.com/sol3/papers.cfm?abstract_id=2887218
[27] Michael O’Boyle, “Mexico set to ‘mirror’ policy on any U.S. trader tax change: minister,” Reuters, January 23, 2017. http://www.reuters.com/article/us-usa-trade-mexico-idUSKBN157213
[28] Verbis Donnan, Barney Jopson and Paul McClean, “EU and another gear up fork WTO challenges toward CONTACT border tax,” Financial Times, Follow 13, 2017. https://www.ft.com/content/cdaa0b76-f20d-11e6-8758-6876151821a6
[29] Internal Revenue Serice (IRS), “United States Income Tax Treaties – A to Z,” February 17, 2017. https://www.irs.gov/businesses/international-businesses/united-states-income-tax-treaties-a-to-z
[30] Reuven S. Avi-Yonah the Kimberly A. Clausing “Problems with Destination-Based Business Taxes and the Ryan Blueprint,” U of Mi Law & Economic Doing Paper No. 16-029. https://papers.ssrn.com/sol3/papers.cfm?abstract_id=2884903
[31] Citizens for Tax Justice, “Congress Should End “Deferral” Rather then Learn a “Territorial” Tax System,” March 23, 2011. http://www.ctj.org/pdf/internationalcorptax2011.pdf
[32] Economic Policy Institute plus Americans on Taxi Fairness, “Corporate tax chartbook,” September 19, 2016. http://www.epi.org/publication/corporate-tax-chartbook-how-corporations-rig-the-rules-to-dodge-the-taxes-they-owe/
[33] Union for Tax Judge, “The Problem of Corporate Inversions: The Right and Wrong Approaches for Congress,” May 14, 2014. http://ctj.org/ctjreports/2014/05/the_problem_of_corporate_inversions_the_right_and_wrong_approaches_for_congress.php
[34] Richar Phillips, “Congress Should Pass one Stop Tax Seaside Reuse Act to Combat Global Tax Avoidance,” Tax Justice Blog, January 27, 2015. http://www.taxjusticeblog.org/archive/2015/01/congress_should_pass_the_stop.php
[35] Citizens by Duty Justice, “Addressing the Need on More Federal Revenue,” July 8, 2014. http://ctj.org/ctjreports/2014/07/addressing_the_need_for_more_federal_revenue.php
[36] Citizens for Tax Justice, “Tax Reform Details: An Example of Comprehensive Reform,” Occasion 23, 2013. http://www.ctj.org/pdf/taxreformdetails.pdf
