Common viral agents known to cause inflammation of the liver (hepatitis) are hepatitis A virus (HAV), hepatitis B virus (HBV), and hepatitis C virus (HCV). Some other viral agents that can cause hepatitis are Epstein Barr virus, herpes simplex virus, and cytomegalovirus. Some patients infected with these viral agents progress to develop chronic viral hepatitis. Approximately 45% of chronic hepatitis cases are associated with hepatitis C and approximately 15% are associated with hepatitis B. In addition to being a leading cause of chronic hepatitis, HCV is most frequently associated with liver cirrhosis and hepatocellular carcinoma. Although much has been published about HAV and HBV, health professionals have learned about HCV only in recent years. For this reason, this article will emphasize the epidemiologic challenges and current treatments for hepatitis C; hepatitis A and B will be discussed in brief.
The 21st Century has seen unprecedented levels of corporate tax aggressiveness and avoidance. This Article continues our exploration of second-best international tax reforms that would protect the U.S. corporate tax base and have some likelihood of adoption. In this case, we consider how a U.S. minimum tax on foreign income earned by a controlled foreign corporation should be designed to protect the United States against erosion of its corporate income tax base and to combat tax competition by low-tax intermediary countries. In the authors’ view, a minimum tax should be an interim levy that preserves the residual U.S. tax on foreign income, as distinguished from a final minimum tax that partially eliminates the U.S. residual tax. An interim minimum tax would be a significant improvement over current law and would more effectively limit incentives to seek low-taxed foreign income while ameliorating pressure to retain excess earnings abroad.To achieve the objectives of such a minimum tax, corresponding changes should be made to the U.S. corporate resident definition, the source taxation of foreign multinational corporations, and the residence taxation of U.S. portfolio investors in foreign corporations to reduce tax advantages under current law for investments in foreign corporations. These changes would reduce tax advantages for foreign parent corporate groups and thereby further protect the U.S. tax base, as well as reduce incentives for U.S. corporations to expatriate as a consequence of increased U.S. taxation of foreign income under an interim minimum tax.
Reform of the U.S. international income taxation system has been a hotly debated topic for many years. The principal competing alternatives are a territorial or exemption system and a worldwide system. For reasons summarized in this Article, we favor worldwide taxation if it is real worldwide taxation; that is, a nondeferred U.S. tax is imposed on all foreign income of U.S. residents at the time the income is earned. However, this approach is not acceptable unless the resulting double taxation is alleviated. The longstanding U.S. approach for handling the international double taxation problem is a foreign tax credit limited to the U.S. levy on the taxpayer's foreign income. Indeed, the foreign tax credit is an essential element of the case for worldwide taxation. Moreover, territorial systems often apply worldwide taxation with a *
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