Professors Who Teach Outside the United States: Tax Planning and Policy Analysis.
分析了美国《国内收入法》第911条排除条款和税收协定中教育工作者豁免条款如何让境外任教的教授规避美国和外国的所得税，并讨论了其政策影响。
Abstract Although originally intended to increase U.S. exports, the current Section 911 exclusions are available to anyone who can establish the required nexus with a foreign country. Professors who teach outside the United States can qualify and avoid U.S. income tax on their compensation. They also can avoid foreign income taxes through the use of little-publicized tax treaty provisions available to educators. Planning is essential to satisfy the Section 911 eligibility requirements. Similarly, qualifying for the educator exemption found in most U.S. tax treaties is assured only if tax planning precedes and accompanies the foreign teaching assignment. A tax policy analysis of the statutory exclusions is difficult because data are sparse and the support is based on testimonials. Nonetheless, the dramatic lowering of U.S. tax rates and the limited number of educators electing Section 911 suggest a trivial cost for this tax expenditure, notwithstanding its violation of equity and neutrality standards.