American Tax Policy Institute

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International Taxation and Competitiveness

A Conference Sponsored by the American Tax Policy Institute
Washington, DC, October 17, 2011
Organized by Reuven Avi-Yonah and Jane Gravelle

Panel One
The Meaning of “Competitiveness” and “Competitive Disadvantage”,
Jane Gravelle (CRS)

Panel Two

Comparing Subpart F with the CFC rules of other countries,
Brian Arnold (moderator)

Subpanel A: Europe and North America
Brian Arnold (moderator)

The French CFC Regime
Daniel Gutman (Professor at Sorbonne Law School, Partner at CMS Bureau Francis Lefebvre)
Francois Meziane (Lawyer at CMS Bureau Francis Lefebvre)

General features of German CFC Rules
Friedhelm Jacob (Frankfurt am Main, Germany)

Germany's Tax Regime – a hybrid between territorial and worldwide
Friedhelm Jacob (Frankfurt am Main, Germany)

Subpanel B: America and Asia
China’s Controlled Foreign Corporation (CFC) Rules
Tizhong Liao (State Admin of Taxation, PRC)

Panel Three: Empirical Research on Competitiveness
In Search of Corporate Tax Incidence
Kimberly Clausing (Reed)

Taxing Multinational Corporations: Average Tax Rates
Lissa Costa (IRS), Jennifer Gravelle (CBO)

Does the Concept of Competitiveness Have Meaning in Formulating Corporate Tax Policy?
Jane Gravelle (CRS) (moderator)

Effective Tax Rates of the Largest Us and Eu Multinationals
Yaron Lahav, Reuven Avi-Yonah (Ben Gurion)