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tax notes international - Tuck School of Business - Dartmouth College

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BOOK REVIEW<br />

smaller government. But the authors are more optimistic<br />

than the critics: They keep their fingers crossed that<br />

future installments <strong>of</strong> <strong>tax</strong> competition will eventually<br />

‘‘starve the beast.’’ Count me a skeptic. Given demographic<br />

aging in all OECD countries and sharp income<br />

inequalities among the elderly, it seems doubtful that<br />

<strong>tax</strong> competition will curtail entitlement spending. Indeed,<br />

entitlement spending could easily double over the<br />

next generation, with medical care accounting for most<br />

<strong>of</strong> the expansion. In the contest between <strong>tax</strong> cuts and<br />

grandmother’s heart surgery, guess who wins.<br />

For me, the compelling argument for <strong>tax</strong> competition<br />

is that it serves to align fiscal charges with public<br />

benefits — just as that hero <strong>of</strong> public finance, Charles<br />

Tiebout, described a half century ago. Tiebout, <strong>of</strong><br />

course, was talking about local governments. But in the<br />

face <strong>of</strong> rising <strong>tax</strong> competition, many national governments<br />

have not only reformed their <strong>tax</strong> systems but<br />

also have enhanced the business environment by improving<br />

transportation, power grids, telecommunications,<br />

schools, hospitals, and museums.<br />

Given the virtues <strong>of</strong> <strong>tax</strong> competition, Edwards and<br />

Mitchell condemn attempts to harmonize national <strong>tax</strong><br />

systems, led by the OECD and the European Union.<br />

In fact, the anti-<strong>tax</strong>-competition crowd has gradually<br />

lost its voice in recent debates. However, it seems<br />

wrong to dismiss wholesale the arguments advanced<br />

for <strong>tax</strong> harmonization.<br />

One subject where I agree with the <strong>tax</strong> harmonization<br />

school is the need to share information on investments<br />

by nonresidents between the host country and<br />

the home country. In the Cato view, the creation <strong>of</strong><br />

efficient reporting networks will suppress <strong>tax</strong> competition.<br />

That’s true, if the term ‘‘<strong>tax</strong> competition’’ is<br />

stretched to encompass means <strong>of</strong> furthering <strong>tax</strong> evasion.<br />

But my belief is that the country <strong>of</strong> citizenship or<br />

residence <strong>of</strong> natural persons has the right to <strong>tax</strong> their<br />

worldwide income if it chooses; accordingly, capital<br />

income earned abroad should be reported by the host<br />

country as a matter <strong>of</strong> comity between nations.<br />

This issue is closely related to an important but <strong>of</strong>ten<br />

overlooked question: Do the virtues <strong>of</strong> <strong>tax</strong> competition<br />

apply with equal force to personal income <strong>tax</strong>ation<br />

as to corporate income <strong>tax</strong>ation? That’s where Tiebout<br />

entered the debate, with the metaphor <strong>of</strong> disaffected<br />

citizens ‘‘voting with their feet.’’ But citizens cannot<br />

change nationality as easily as residence; and in some<br />

countries, the rights and privileges associated with citizenship<br />

are extremely valuable. Against this factual<br />

background, I think it’s an open question whether unfettered<br />

<strong>tax</strong> competition is appropriate in the realm <strong>of</strong><br />

personal <strong>tax</strong>ation.<br />

Edwards and Mitchell have written a most entertaining<br />

book — not an easy feat when the subject is <strong>tax</strong>ation.<br />

Casual readers will enjoy stories about celebrities<br />

— Ringo Starr <strong>of</strong> Beatles fame, Irish rock band U2,<br />

Swedish pop group ABBA, and others — who have<br />

channeled their wealth and royalties to <strong>tax</strong> haven jurisdictions.<br />

Policy wonks will appreciate the comprehensive<br />

surveys <strong>of</strong> <strong>tax</strong> reform. There’s something for<br />

everyone — even the Obama team and its congressional<br />

allies. ◆<br />

416 • FEBRUARY 2, 2009 TAX NOTES INTERNATIONAL<br />

(C) Tax Analysts 2009. All rights reserved. Tax Analysts does not claim copyright in any public domain or third party content.

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