that depart from current IITR conventions for sourcing MNEs'
The features of this phase reflect IITR policymakers'
recognition that the main challenge and duty of the IITR is not to
these experiments have abandoned traditional IITR arm's-length
likely that the present United States IITR will be replaced with a much
Second, the current IITR treatment of affiliated financial
dominated the IITR debate are fundamentally insufficient for dealing
considerations played too small a role in the development of the IITR.
create a new phase in IITR development that contains new source
practical conclusions regarding the future path of the IITR.
demonstrate the original concerns of the different IITR policymakers in
To be sure, at the time, the IITR was primarily concerned with