This Note argues that the United States should adopt a territorial tax system. Currently, the United States is one of a small group of nations that employs a worldwide system of taxation. Under a worldwide system, income is taxed both in the country where it is earned and in the country where the taxpayer resides. Alternatively, under a territorial system, income is taxed only in the country where it is earned. By adopting a territorial system, the United States would jettison the duplicative taxation inherent in the worldwide system. Additionally, the presence of anti-inversion rules, controlled foreign corporation rules, and the rise of service-based economies will enable the United States to adopt a territorial system without fear of large scale capital flight.
Note, Peer Pressure: Why America Should Succumb to the Territorial Tax Temptation, 4 Global Bus. L. Rev. Issue 2 (2014)