id	author	title	date	pages	extension	mime	words	sentence	flesch	summary	cache	txt
ftr-430	Fleming, Jr., J. Clifton; Peroni, Robert J.; Shay, Stephen E.	Fairness in International Taxation: The Ability-to-Pay Case for Taxing Worldwide Income	2022	56	.pdf	application/pdf	30402	1112	51	The United States has responded to the need for compromise by granting a credit for foreign income tax, limiting U.S. tax collection to a residual tax on foreign-source income of U.S. residents and declining to surrender U.S. tax on U.S.-source income. Speaking more broadly, mitigating international double-taxation by allowing a credit for foreign income tax payments is the economic equivalent of exempting foreign-source income in proportion to the amount of U.S. income tax that is offset by the credit.	cache/ftr-430.pdf	txt/ftr-430.txt