This paper describes the basic U.S. legal rules that govern the taxation of international transactions and explores the economic policies or principles they reflect. Particular attention is paid to the changes made by the Tax Reform Act of 1986, but it is impossible to understand the 1986 Act changes without placing them in the context of the general taxing system applicable to international transactions. The exposition is intended to be intelligible to readers with either legal or economic training.
Taxation in the Global Economy, edited by Assaf Razin and Joel Slemrod, pp. 11-46. Chicago: The University of Chicago Press, 1990.