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This article will examine the United Nations Commission on Transnational Corporations (TNCs) along with various U.S. tax treaties and their consequences. We will then look to the various tax systems existing in France, Britain, Germany, and Japan to see how TNCs have been taxed there. Although the examination focuses on the U.S.-based TNCs, the policy considerations may be valid in reverse, e.g., as applied to foreign based TNCs operating in the United States. Considering the increasing role and financial dominance of the TNC, an understanding of tax basics as applied in four countries, will hopefully give the practitioner a working flavor of the area.


Due to an oversight in transposition, two significant errors appear in Mr. Carroll's article in volume 27, number 2:

  • Page 450, third line. For "has has" read "has no."
  • Page 451, sixth line. For "is now" read "is not."