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Continuity As The Key To Reform Of Section 355, Charlene Luke
Continuity As The Key To Reform Of Section 355, Charlene Luke
UF Law Faculty Publications
There can be little doubt that Internal Revenue Code (Code) section 355 is overly complex; the piecemeal adjustments spanning multiple decades could serve as exemplars of the potential pitfalls of incremental reform. Revisions to section 355 have tended to be under- or over-inclusive because they are reactive to particular deals, yet they leave largely intact older structures that dealt with different deals. The result is a jumble of provisions that fail to implement a coherent, principled approach to the tax treatment of corporate divisions. In Reform of Section 355, Bret Wells urges changing Code section 355 to focus on the …
Can Gilti + Beat = Globe?, Mindy Herzfeld
Can Gilti + Beat = Globe?, Mindy Herzfeld
UF Law Faculty Publications
The OECD is moving forward with consideration of a minimum tax as part of its solution to taxation of the digital economy. Part of a template for such a minimum tax may be the version enacted by the United States (US) in 2017 as an expansion of its Controlled Foreign Corporation (CFC) regime, known as Global Intangible Low Taxed Income (GILTI). But the OECD version will undoubtedly be different from the US iteration. It’s likely that it would also include some aspects of a minimum tax being proposed by other OECD members such as Germany and France, namely a tax …
Book Review: International Tax Policy: Between Competition And Cooperation, Yariv Brauner
Book Review: International Tax Policy: Between Competition And Cooperation, Yariv Brauner
UF Law Faculty Publications
The author reviews International Tax Policy: Between Competition and Cooperation. By Tsilly Dagan. Cambridge Tax Law Series, 2018.