Strategies for the new base erosion and anti-abuse tax James G.S. Yang, Wing W. Poon and Chiaho Chang
By: Yang, James G. S
.
Contributor(s): Poon, Wing W | Chang, Chiaho.
Material type: 
ArticlePublisher: 2018Subject(s): IMPUESTOS | EROSIÓN DE LA BASE IMPONIBLE Y TRASLADO DE BENEFICIOS | ABUSO DEL DERECHO | ESTADOS UNIDOS | ELUSION FISCALOnline resources: Click here to access online
In:
Journal of Taxation of Investments v. 36, n. 1, Fall 2018, p. 67-77Summary: The Tax Cuts and Jobs Act of 2017 imposes a new tax regime
known as the “base erosion and anti-abuse tax.” This article discusses the reasons for this new tax and the details involved in
determining the amount of tax due. The authors point out that
there are many loopholes in international tax law—including the
differences in different jurisdictions’ tax rates, the “worldwide tax
system” versus the “territorial tax system,” and the use of a controlled foreign corporation as a tax shelter—and that many U.S.
multinational corporations have taken advantage of them. The
authors cite fi ve relevant cases—Burger King, Medtronic, Apple,
Horizon, and SAP—and investigate the components of this new
tax involving the concept of “base erosion payment.” They then
suggest ways corporations might respond to the new tax.
| Item type | Current location | Home library | Call number | Status | Date due | Barcode |
|---|---|---|---|---|---|---|
| Artículos | IEF | IEF | OP 235/2018/36/1-7 (Browse shelf) | Available | OP 235/2018/36/1-7 |
Disponible también en formato electrónico a través de la Biblioteca del IEF.
Resumen.
The Tax Cuts and Jobs Act of 2017 imposes a new tax regime
known as the “base erosion and anti-abuse tax.” This article discusses the reasons for this new tax and the details involved in
determining the amount of tax due. The authors point out that
there are many loopholes in international tax law—including the
differences in different jurisdictions’ tax rates, the “worldwide tax
system” versus the “territorial tax system,” and the use of a controlled foreign corporation as a tax shelter—and that many U.S.
multinational corporations have taken advantage of them. The
authors cite fi ve relevant cases—Burger King, Medtronic, Apple,
Horizon, and SAP—and investigate the components of this new
tax involving the concept of “base erosion payment.” They then
suggest ways corporations might respond to the new tax.
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