By not taxing exports, he said, it would “strongly encourage American companies to locate activities in the United States.”

But critics say this is wishful thinking, divorced from the reality of international trade laws, Washington lobbying and corporate financial engineering. Major features of Mr. Auerbach’s design, they say, will probably be jettisoned to appease domestic interests or conform to trade rules. A new system might curb some tax gaming, they say, but not stop it.

What will remain, they predict, will be the House proposal to sharply reduce the corporate tax rate. “The result will be a giant corporate tax cut that benefits the rich because most of the owners are rich,” said Robert McIntyre, the director of Citizens for Tax Justice. “Everyone loses except those at the top.”

Mr. Auerbach, 65, became fascinated by the mechanics and impact of tax policy while pursuing his doctorate at Harvard, encouraged by his thesis adviser, Martin Feldstein, a chairman of the Council of Economic Advisers in the Reagan administration.

Mr. Auerbach was an adviser to John Kerry, the Democratic nominee for president in 2004. But Mr. Auerbach has long been a registered independent. “I like to keep conversations open with both sides,” he said. “I think of myself as an economist first, and that the evidence should dictate the policy.”

His research on tax policy has increasingly focused on the global context. So has the study of other economists. In 2001, in a conference at Berkeley, Michael Devereux was the co-author of a paper with Stephen R. Bond that introduced the term destination-based corporate tax.

In recent years, Mr. Auerbach and Mr. Devereux have cooperated in developing the idea and working through how it might be put into effect. “We’re kindred spirits, for sure,” said Mr. Devereux, a professor at the Saïd Business School at the University of Oxford.