In a contribution to the Wall Street Journals MarketWatch Inc., Eric Toder and Alan Viard argue that recent highly publicized tax avoidance transactions by U.S. corporations reflect basic flaws in how we tax the income of multinational corporations, and that proposed reforms that maintain current definitions of corporate residence and source wont fix the underlying problems. They propose two fundamental structural reforms seeking international agreement on rules for allocating the income of multinational corporations among countries, or scrapping the U.S. corporate income tax entirely and replacing it with taxation at ordinary income rates of dividends and accrued gains of U.S. resident shareholders.