Abstract
This Essay is a primer on the income taxation of cross-border transactions, comparatively examining the approaches of the US. federal government and the American states, and focusing on the problems of residency, enforcement jurisdiction, sourcing, and transfer pricing. The sourcing rules of each level of government share common flaws, while the approaches to the problem of transfer pricing offer the sharpest contrast. The differences between the two systems often are explained by the higher level of integration within the federal system, but as the global economy continues to integrate, the approaches may begin to converge.
How to Cite
50 Ariz. L. Rev. 111 (2008)
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