Mihir A. Desai (Harvard) & Dhammika Dharmapala (Illinois) have posted Do Strong Fences Make Strong Neighbors? on SSRN. Here is the abstract:

Many features of U.S. tax policy towards multinational firms – including the governing principle of capital export neutrality, the byzantine system of expense allocation, and anti-inversion legislation – reflect the intuition that building “strong fences” around the United States advances American interests. This paper examines the interaction of a strong fences policy with the increasingly important global markets for corporate residence, corporate control and corporate equities. These markets provide opportunities for entrepreneurs, managers and investors to circumvent a strong fences policy. The paper provides simple descriptive evidence of the growing importance of these markets and considers the implications for U.S. tax policy.