Yariv Brauner (Florida; Google Scholar), You Play, You Pay! Mobility, Territory, And Exclusive Source Taxation In The 21st Century:
States have been taxing the income of both individuals and corporations based on their residence and on the source of their income. Recent developments have made residence an inappropriate basis for taxation, leaving the international tax regime wanting for reform. Assuming that states lack the appetite for an overhaul of the regime, this Article examines whether source (the remaining widely acceptable basis for taxation) could alone serve this role. It concludes that an exclusive source-based international tax reform is both viable and desirable, but its success likely depends on the willingness of states to better cooperate and coordinate their tax policies and practices.
The Article makes four specific original contributions: first, it demonstrates the benefits of a single basis for taxation of both individuals and corporations; second, it evaluates the existing, mostly universal, source rules and their suitability to a modern source-based income tax regime; third, it analyzes possible reforms of these source rules that states may adopt; and, finally, it accounts for the hurdles that the examined reform may face and ways to overcome these hurdles.
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