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Constructive Dialogue: Beps And The Tcja, Reuven S. Avi-Yonah
Constructive Dialogue: Beps And The Tcja, Reuven S. Avi-Yonah
Law & Economics Working Papers
US international tax law is commonly conceived as developed in the US and influencing the development of other countries' international tax law. This paper will argue that in the case of the TCJA, the US legislation was heavily influenced by the OECD BEPS project, and that the continuing OECD work in Pillars I and II is likely to have a similar influence on the future development of US international tax law.
The International Provisions Of The Tcja: Six Results After Six Months, Reuven S. Avi-Yonah
The International Provisions Of The Tcja: Six Results After Six Months, Reuven S. Avi-Yonah
Law & Economics Working Papers
Over six months have passed since the enactment of the TCJA, so it is now possible to reach some preliminary conclusions on its impact. The main ones are:
1. The transition tax plus anticipated GILTI tax minus territoriality have resulted in higher GAAP effective tax rates for 2017. In some cases they approach 35% for large multinationals with a lot of offshore income. For the first six months of 2018, however, overall corporate tax revenues are sharply down because of the 21% rate plus expensing. This is the exact reverse of the situation before TCJA in which MNEs showed very …