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University of Michigan Law School

Law & Economics Working Papers

2021

GILTI

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Is Gilti Constitutional?, Reuven S. Avi-Yonah Feb 2021

Is Gilti Constitutional?, Reuven S. Avi-Yonah

Law & Economics Working Papers

In this article, Avi-Yonah argues that the global intangible low-taxed income regime may be an unconstitutional attempt to tax the foreign-source income of foreign entities, and he offers an alternative.