Shifting Economic Allegiance of Capital Gains

Technological advances and the digitalization of the global economy have created an economic environment beyond the imagination of the original designers of the international tax system. Much scholarly attention has been paid to the question of how these economic transformations should affect which country is able to tax a multinational company’s income. But which country should be able to tax capital gains income from the sale of that company’s shares is an important and overlooked question. This Article answers this question. It concludes that taxing authority over capital gains income must be reallocated to the countries in which companies conduct business. In our modern, digitalized economy, this reallocation is necessary to align international sourcing rules with international tax law’s underlying principles. While this Article is a primarily a proof of concept, it also seeks to begin a conversation about ways to implement this reallocation and describes one possible approach: an annual mark-to market tax at the company level on increases in company value apportioned amongst source countries based on a set formula.

Authors

Institutions

Publication Details

Journal
Florida Tax Review
Published
2024-08-08
DOI
https://doi.org/10.5744/ftr.2023.2007
Citations
1
Primary Topic
Corporate Taxation and Avoidance
Type
article
Field-Weighted Citation Impact
0.95
Controls
|||
ALL TIME
JAN
FEB
MAR
APR
MAY
JUN
JUL
AUG
SEP
OCT
article

Shifting Economic Allegiance of Capital Gains

Amanda Parsons
1 citations
Florida Tax Review
Corporate Taxation and Avoidance
0.95
article

Shifting Economic Allegiance of Capital Gains

Amanda Parsons
article en
1 citations

Abstract

Technological advances and the digitalization of the global economy have created an economic environment beyond the imagination of the original designers of the international tax system. Much scholarly attention has been paid to the question of how these economic transformations should affect which country is able to tax a multinational company’s income. But which country should be able to tax capital gains income from the sale of that company’s shares is an important and overlooked question. This Article answers this question. It concludes that taxing authority over capital gains income must be reallocated to the countries in which companies conduct business. In our modern, digitalized economy, this reallocation is necessary to align international sourcing rules with international tax law’s underlying principles. While this Article is a primarily a proof of concept, it also seeks to begin a conversation about ways to implement this reallocation and describes one possible approach: an annual mark-to market tax at the company level on increases in company value apportioned amongst source countries based on a set formula.

Florida Tax ReviewVol. 26(2)
University of Colorado System (US), University of Colorado Colorado Springs (US), University of Colorado Denver (US)
Openalex Percentile: Top 20%
Corporate Taxation and Avoidance
0.95
AI Navigator

Ask Laika to Summarize, Analyze, and Connect papers live on the map.

Summarize Papers & Methodologies

Extract key findings, datasets, and comparative methods across publications.

Benchmark Rankings & Visual Analytics

Rank top research institutions, authors, funders, topics, and journals by Field-Weighted Citation Impact (FWCI) and paper volume with instant charts.

Connect Distant Disciplines

Bridge topological clusters on the map to find hidden collaborative intersections.