A critical review of proposals for destination-based cash-flow corporate taxation as an international tax reform option
Bibliographic record
Abstract
This article critically examines recent proposals for a destination-based, cash-flow corporate tax (DCT) as an option for international tax reform. I identify a range of exegetical issues the clarification of which would advance the evaluation of DCT proposals. These include whether DCT proponents have stated relevant and sufficient normative criteria for comparing the current international tax system with reform alternatives, as well as the relationship of the DCT to individual taxation. Moreover, I argue that (i) three versions of the DCT proposal should be distinguished; (ii) it may be misleading to label the most plausible versions of DCT as a tax on corporate profits; (iii) the proposals give rise to concerns about trade distortions; and (iv) an overly abstract approach to corporate losses have prevented DCT proponents from elaborating crucial institutional design issues. I then offer a fundamental critique of the DCT project. DCT proponents tend to be skeptical about residence-based taxation of individuals. Yet they aim to introduce information about individuals qua final consumers into the design of the corporate tax. This is ironic, because individual residency and the location of individuals as consumers are mostly the same. Moreover, market structures and the legal and regulatory apparatus built upon them are more likely to transmit information about individuals as residents than as final consumers. Thus if corporate income is to be taxed by reference to a relatively immobile factor, considering shareholder residence is an at least equally, and probably more, promising approach.
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How this classification was reachedexpand
Full frame machine prediction
Teacher imitationNot calibrated prevalence, not ground truth. Human validation pending. The Gemma side is a direct model label for every work in the frame, read from the title-only record. The Codex side is a classifier learned from the 10,348 direct Codex labels and calibrated to design-weighted sample rates; fields without enough sample support carry no Codex call. Candidate is the union of the two sides; consensus is their intersection. These outputs are machine_predicted_unvalidated and are not human labels.
Distilled classifier scores by category (both heads)
| Category | Codex | Gemma |
|---|---|---|
| Metaresearch | 0.012 | 0.025 |
| Meta-epidemiology (narrow) | 0.001 | 0.001 |
| Meta-epidemiology (broad) | 0.001 | 0.001 |
| Bibliometrics | 0.006 | 0.006 |
| Science and technology studies | 0.002 | 0.006 |
| Scholarly communication | 0.007 | 0.006 |
| Open science | 0.002 | 0.002 |
| Research integrity | 0.007 | 0.009 |
| Insufficient payload (model declined to judge) | 0.004 | 0.002 |
Machine scores (provisional)
The two teacher heads of the student model, read on this work. A score orders the frame for review; it never asserts a category, and the validation status ships verbatim with every row.
Baseline scores from an immature model (maturity gate not passed, 7 training rounds). Scores rank; they never assert a category.
score_only:v0-immature-baseline · verbatim from the scoring run: score_only means the number may rank works, and no category label ships from itClassification
machine, unvalidatedMachine predicted; a candidate call from one source (direct Gemma or distilled Codex), not a consensus.
How this classification was reached, model by model and score by score, is at the end of the page under "How this classification was reached".