Much of what I will say here today is distilled from articles that I have written and things I have learned in putting together a book called Foundations of International Taxation.
It is difficult enough to fashion sensible tax policy in the domestic arena. The debate, for example, over whether the United States should impose a value-added tax has some international aspects, but it is primarily a debate about domestic policy. This is true generally about the debate over how much we should rely on income versus consumption taxation. This debate amply illustrates how hard it is to obtain agreement on principles when we have, what Fred Goldberg calls, one Caesar claiming the revenues. In international affairs, we have at least two Caesars-two national governments – with legitimate claims to tax the income. We must decide how to divide the tax dollars between the two Caesars. Multinational corporations strive to pay taxes to neither. Disputes are inevitable. It is therefore very important to think about the underlying principles of international taxation and to be explicit about what we are trying to achieve.
Law | Taxation-Transnational
International Income Taxation,
Available at: https://scholarship.law.columbia.edu/faculty_scholarship/3430