Some Thoughts on the Incidence of Foreign Taxes
12 Pages Posted: 29 Jan 2009
Date Written: January 27, 2009
Abstract
This 2000 article was prompted by the fact pattern and Tax Court decision in Compaq Computer v. Commissioner, 113 T.C. 363 (1999). While other commentary has focused on the application of the "economic substance" doctrine in this case, this article focuses instead on the ability to take foreign tax credits based not on economic incidence but on legal incidence and how this allows for crediting of foreign taxes economically borne by other actors in the marketplace.
Keywords: income taxation, international taxation, foreign tax credit, Compaq Computer
JEL Classification: H20, H24
Suggested Citation: Suggested Citation
Geier, Deborah A., Some Thoughts on the Incidence of Foreign Taxes (January 27, 2009). Tax Notes, Vol. 87, p. 541, 2000, Cleveland-Marshall Legal Studies Paper No. 1333851, Available at SSRN: https://ssrn.com/abstract=1333851
Do you have a job opening that you would like to promote on SSRN?
Feedback
Feedback to SSRN
If you need immediate assistance, call 877-SSRNHelp (877 777 6435) in the United States, or +1 212 448 2500 outside of the United States, 8:30AM to 6:00PM U.S. Eastern, Monday - Friday.