Japan's and the U.K’s recent adoptions of territorial systems with respect to the foreign income of residents have created a significant likelihood that the U.S. will replace its badly-flawed worldwide system with a territorial system.

This lecture will argue that considerations of fairness, locational neutrality and tax expenditure analysis indicate that the U.S. should reject territoriality and, instead, should take action to mend the defects in its worldwide system.

The lecture will also argue that if the U.S. does adopt territoriality, its territorial system should contain certain features that will be unpopular with the U.S. multinational business community.