Combined Reporting and Formulary Apportionment

State

Michael J. McIntyre, Paull Mines, and Richard D. Pomp, Designing a Combined Reporting Regime for a State Corporate Income Tax: A Case Study of Louisiana, 61 Louisiana Law Review 699 (2001), reprinted 21/10 State Tax Notes 741-769 (Sept. 3, 2001).
Ernst & Young, Wal-Mart: Ideas for State and Local ETR Reduction (2001). Confidential memo that was entered into the record of the 2007 Wal-Mart case in North Carolina. In that case, Wal-Mart has sued for a refund of its higher assessment that resulted from the state's effort to nullify, through discretionary combined reporting, the tax benefits obtained by Wal-Mart from the use of a REIT. See here for scanned original.
Richard D. Pomp and Michael J. McIntyre, State Taxation of Mail-Order Sales of Computers after Quill: An Evaluation of MTC Bulletin 95-1, 11 State Tax Notes 177-184 (July 15, 1996).
Richard D. Pomp and Michael J. McIntyre, "Double Trouble: Double Taxation Aspects of Formulary Apportionment in the International Context," 1994 NTA Proceedings 236-238 (1994) (short paper presented at 87th annual conference of the National Tax Association, November 15, 1994, at Charleston, SC).
Richard D. Pomp and Michael J. McIntyre, "GATT, Barclays, and Double Taxation," 8 State Tax Notes 977-980 (March 6, 1995).

National

The Use of Combined Reporting by Nation States, in chapter 8, Arnold, Sasseville, & Zolt, eds. The Taxation of Business Profits Under Tax Treaties (2003). Summary. Revised and reprinted in 35 Tax Notes Int'l 917-948 (Sept. 6, 2004).
Determining the Residence of Members of a Corporate Group, 51/4 Canadian Tax Journal 1567-73 (2003). Summary.
Michael J. McIntyre, "Design of a National Formulary Apportionment Tax System," 1991 NTA-TIA Proceedings 118-124 (1991) (paper presented at 84th Annual Conference of the National Tax Association, November 12, 1991, at Williamsburg, VA.).
Michael J. McIntyre, "Contrasting Methodologies: A Systematic Presentation of the Differences Between an Arm's-Length/Source-Rule System and a Combined-Reporting/Formulary-Apportionment System." 1994 NTA Proceedings 226-235 (1994) (paper presented at 87th annual conference of the National Tax Association, November 15, 1994, at Charleston, SC).
Michael J. McIntyre, "A Critique of the Source Principle," 1 Tax Notes Int'l 261-262 (September 1989).
Michael J. McIntyre, "The Demise of U.S. Source Jurisdiction," 1 Tax Notes Int'l 371-373 (October 1989).
Michael J. McIntyre, "Revitalizing U.S. Source Jurisdiction," 1989 NTA-TIA Proceedings 115 (1990).

NAFTA

Michael J. McIntyre, "The Design of Tax Rules for the North American Free Trade Alliance," 49 Tax Law Review 769-793 (1994).
Robert S. McIntyre and Michael J. McIntyre, "Using NAFTA to Introduce Formulary Apportionment," 6 Tax Notes Int'l 851-56 (Apr. 5, 1993).
Michael J. McIntyre, "Planning for the North American Free Trade Community, Part 1," 3 Tax Notes Int'l (August 1991).
Michael J. McIntyre, "Planning for the North American Free Trade Community, Part 2," 3 Tax Notes Int'l 963-965 (September 1991).

European Union

EU Commission Staff Paper, Company Taxation in the Internal Market (Oct. 23, 2001) (2 meg pdf).
Michael J. McIntyre, "Harmonizing Direct Taxes in the EEC," 2 Tax Notes Int'l 131-132 (Feb. 1990).
Michael J. McIntyre, "Harmonizing Direct Taxes on Business Within the EEC," 2 Tax Notes Int'l 341-342 (April 1990).
Michael J. McIntyre, "Taxing Income from Moveable Capital in the EEC After 1992," 2 Tax Notes Int'l (May 1990) 461-463.
Link to EU Common Tax Base materials.
EU Commission, "Progress to date and next steps towards a Common Consolidated Corporate Tax Base (CCCTB)" 5 April 2006).
Speech by Commissioner László Kovács (April 2006).
Pilot home base proposal for small business.

General Theory

Michael J. McIntyre, "Guidelines for Taxing International Capital Flows:The Legal Perspective," 46 National Tax Journal 315-321 (1993).
Frances M. Horner, "Do We Need an International Tax Organization?" 24 Tax Notes Int’l 179 (October 8, 2001).
Oliver OLDMAN et Jennifer J.S. BROOKS, "The Unitary Method and the less developed Countries: Preliminary Thoughts," 1 Revue de Droit Des Affairs Internationales (1987).