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Alvin C. Warren, Jr., Deferral and Exemption of the Income of Foreign Subsidiaries: A Review of the Basic Analytics (Harvard Pub. Law Working Paper No. 14-18, Feb. 4, 2014).

Abstract: Current proposals to replace the U.S. foreign tax credit with an exemption for the income of foreign subsidiaries of U.S. companies make timely a review of the basic analytics of taxation under the two systems. This brief note reviews the key relationships, highlighting some that are not always fully appreciated in policy discussions.