Research Archives

International Tax

• Challenging the Status Quo: The Case for Combined Reporting, Tax Management Transfer Pricing Report, Vol. 20 No. 22, pp. 1165-1173 (March 22, 2012).
• Identifying the New International Standard for Effective Information Exchange
  in "Tax Treaties from a Legal and Economic Perspective", Institute for Austrian and International Tax Law, Vienna University of Economics and Business Administration.
  
• How to End the Charade of Information Exchange, 56 Tax Notes Int'l 255-268 (October 26, 2009), reprinted in 125 Tax Notes 695-707 (November 9, 2009).
• Identifying tax losses entitled to full loss offsets in a business profits tax under the Domar-Musgrave risk model, 24 Australian Tax Forum 77-88 (2009).
• The Deduction of Interest Payments in an Ideal Tax on Realized Business Profits, Chapter 11, pp. 385-406, in John G. Head and Richard Krever, Eds., Tax Reform in the 21st Century: A Volume in Memory of Richard Musgrave, Kluwer Law International (2009).
• A Program for International Tax Reform, 122 Tax Notes 1021 (Feb. 23, 2009) (bigger print version ).
• The Use of Combined Reporting by Nation States, in chapter 8, Arnold, Sasseville, & Zolt, eds. The Taxation of Business Profits Under Tax Treaties (2003). Summary. Revised and reprinted in 35 Tax Notes Int'l 917-948 (Sept. 6, 2004).
• Determining the Residence of Members of a Corporate Group, 51/4 Canadian Tax Journal 1567-73 (2003). Summary.
• The International Income Tax Rules of the United States, 2d Edition, Lexis Publishing, 2000 (looseleaf, 2 volumes), with major 2002 update. First edition published by Butterworth Legal Publishers, 1989.
• International Tax Primer, 2d Edition, Kluwer Law International, The Hague and Cambridge, MA (2002) (with Brian Arnold). The first edition was published by Kluwer in 1995.
• How the United States Should Respond to the ETI Dilemma, 26 Tax Notes Int'l 865-872 (May 20, 2002), reprinted in 95 Tax Notes 1251-1255 (May 20, 2002). Summary.
• Statement of Michael J. McIntyre, Options for Major Reform of the U.S. International Income Tax Rules, House Ways and Means Committee Luncheon Meeting, Issues in International Taxation, U.S. House of Representatives, 107th Congress, Second Session, April 25, 2002.
• Statement of Michael J. McIntyre, Responding to the Final Decision of the World Trade Organization Against the U.S. Extraterritorial Income Exemption Legislation, Hearing Before the Subcommittee on Select Revenue Measures, Committee on Ways and Means, U.S. House of Representatives, 107th Congress, Second Session, April 10, 2002.
• U.S. Taxation of Foreign Corporations in the Digital Age, 55 (9/10) Bulletin for International Fiscal Documentation 498 (2001). Summary.
• U.S. Income Taxation of Electronic Sales: A Virtual Office as Fixed Place of Business (adapted from 55 (9/10) Bulletin for International Fiscal Documentation 498 (2001).
• Defense of OECD Harmful Tax Competition Report, 81 Tax Notes 1437-38 (1998).
• The Royalty Source Rule, Treaty Shopping, Cascading Effects, and the Tax Court’s Indefensible Decision in SDI Netherlands, 15/25 Tax Notes Int’l 2031-2034 (Dec. 22, 1997).
• Taxing Electronic Commerce Fairly and Efficiently, 52 Tax Law Review 625-654 (1997).
• McIntyre Returns Fire on Financial Services Industry Provision, 15 Tax Notes Int'l 1279-1285 (October 20 1997) (Letter To The Editor).
• Defense of Subpart F Against Financial Services Industry, No. 1 and No. 2 (1997).
• Commentary: Professor McIntyre Joins the Fray Over Recently Vetoed Subpart F Provisions, 15/11 Tax Notes Int’l 837-839 (Sept. 15, 1997).
• International Aspects of Kemp Commission Report, 70 Tax Notes 607-609 (January 29, 1996), reprinted in 12 Tax Notes Int'l 417-420 (Feb. 5, 1996).
• Separate Basket Limitations in Theory and in Practice, 12 Tax Notes Int’l 57-64 (Jan. 1, 1996), reprinted in 70 Tax Notes 1393-1399 (March 4, 1996).
• Statement of Michael J. McIntyre, Collecting Current Tax from American Resident Individuals and U.S.-Based Multinational Corporations on Income Earned through Foreign Entities, before Senate Finance Committee, July 21, 1995.
• The Design of Tax Rules for the North American Free Trade Alliance, 49 Tax Law Review 769 (1994).
• Overruling Intel to Pay for GATS, 9 Tax Notes Int'l 979-983 (September 26, 1994).
• U.S. Tax Court’s Brown Group Decision Threatens Subpart F, 9 Tax Notes Int’l 1225-1230 (October 17, 1994). (The argument of this paper was accepted by the Tax Court in a rehearing of Brown Group and then rejected by the Court of Appeals.)
• Guidelines for Taxing International Capital Flows: The Legal Perspective, 46 National Tax Journal, 315-321 (1993).
• Statement of Michael J. McIntyre on H.R. 5270, The Foreign Income Tax Rationalization and Simplification Bill of 1992, before the House Ways and Means Committee, July 21, 1992.
• Loss of Deductions by Foreign Persons Engaged in Business in the U.S., 39 Canadian Tax Journal (1991) 1128-30.
• Design of a National Formulary Apportionment Tax System, 1991 NTA-TIA Proceedings 118-124 (1991) (paper presented at 84th Annual Conference of the National Tax Association, November 12, 1991, at Williamsburg, VA).
• Revitalizing U.S. Source Jurisdiction, 1989 NTA-TIA Proceedings 115 (1990).
• Taxing Income from Moveable Capital in the EEC after 1992, 2 Tax Notes Int’l 461 (May 1990).
• Offshore Banking and Gresham's Law, adapted from 2 Tax Notes Int'l 819-821 (Aug. 1990).
• Transfer Pricing: The Bausch & Lomb Case and the Future of the Arm’s Length Standard, 1 Tax Notes Int’l 36-37 (July 1989).
• A Critique of the Source Principle, 1 Tax Notes Int’l 261-262 (September 1989).
• The Demise of U.S. Source Jurisdiction, 1 Tax Notes Int’l 371-373 (October 1989).
• Australian Measures to Curb Tax Haven Abuses: A United States Perspective, 5 Australian Tax Forum 419-449 (1988).
• Toward a Fairer and Less Complicated Foreign Tax Credit System, Tax Notes, March 24, 1986, pp. 1269-72.
• The Foreign Tax Credit and the Brazilian Rebate, Tax Notes, January 23, 1978, pp. 67; Response to Comments of Messrs. Guttentag and Nauheim, Tax Notes, April 3, 1978, pp. 354.
• United States of America: Income Taxation of Private Investments in Developing Countries (revising a 1970 study by the United Nations) (1976).
• Tax Guide for Alien Scholars, in The Asian Student Orientation Handbook (1974-75, 1975-76, 1976-77, 1977-78. 1978-79. 1979-80).