Open Access. Powered by Scholars. Published by Universities.®
Articles 1 - 2 of 2
Full-Text Articles in Law
More Anti-Simplification: How Pti And Gilti Override The Section 245a Exemption And The U.S. Territorial Tax System, Christine A. Davis
More Anti-Simplification: How Pti And Gilti Override The Section 245a Exemption And The U.S. Territorial Tax System, Christine A. Davis
Mercer Law Review
In December of 2017, the United States (U.S.) enacted tax reform commonly known as the “Tax Cuts and Jobs Act” (TCJA), which was initially thought to “establish[] a territorial tax system for multinational companies.” Over time, however, tax professionals began to understand that the TCJA layered a territorial tax system that exempted foreign earnings from the U.S. income tax (exemption tax system) on top of a residence-based worldwide tax system that used a foreign tax credit (FTC) to protect against juridical double taxation (worldwide tax system). Furthermore, the U.S. exemption tax system is severely limited by the worldwide tax system. …
Taxation Of U.S.-Based Transnational Corporations, Mitchell B. Carroll
Taxation Of U.S.-Based Transnational Corporations, Mitchell B. Carroll
Mercer Law Review
This article will examine the United Nations Commission on Transnational Corporations (TNCs) along with various U.S. tax treaties and their consequences. We will then look to the various tax systems existing in France, Britain, Germany, and Japan to see how TNCs have been taxed there. Although the examination focuses on the U.S.-based TNCs, the policy considerations may be valid in reverse, e.g., as applied to foreign based TNCs operating in the United States. Considering the increasing role and financial dominance of the TNC, an understanding of tax basics as applied in four countries, will hopefully give the practitioner a working …