Approximating capital-export neutrality in imputation systems : proposal for a limited exemption approach

This article first outlines the approaches that have previously been taken or proposed for the treatment of foreign-source income by countries that exempt non-portfolio dividends and employ a dividend imputation system. The article then develops an approach which it calls the "limited exemption approach" for the treatment of foreign-source dividends in an imputation system for countries that exempt some or all non-portfolio dividends.