The US international tax reforms : competition and convergence, pay-offs and policy failures Stephen E. Shay
By: Shay, Stephen E
.
Material type: 
ArticlePublisher: 2018Subject(s): IMPUESTOS | REFORMA | ESTADOS UNIDOS | FISCALIDAD INTERNACIONAL
In:
Intertax v. 46, Issue 11, November 2018, p. 905-913Summary: This article addresses the recent US tax reform's international provisions. Part II reviews the political context and time pressure under which the tax legislation was adopted, which explains why it was not a fundamental tax reform. Part III(A) reviews the most important "international" business provisions, starting with the pervasive effects of the reduction in the corporate tax rate and its interaction with credits for foreign income taxes. Part III(B) examines the new global intangible low-taxed income (GILTI) and foreign dividends received deduction provisions, the reduced effective tax rate for foreign derived intangible income (FDII) from exports and the base erosion alternative minimum tax or BEAT. Part IV comments on the most important international reform left unaddressed and Part V concludes.
| Item type | Current location | Home library | Call number | Status | Date due | Barcode |
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| Artículos | IEF | IEF | OP 2141/2018/11-6 (Browse shelf) | Available | OP 2141/2018/11-6 |
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| OP 2141/2018/11-3 Applying modern disruptive technologies to improve the effectiveness of tax treaty dispute resolution | OP 2141/2018/11-4 (Un)tangling tax avoidance under the Interest and Royalties Directive | OP 2141/2018/11-5 BEPS, ATAP, and the new tax dialogue | OP 2141/2018/11-6 The US international tax reforms | OP 2141/2018/11-7 Brazilian transfer pricing rule | OP 2141/2018/1-2 The principal purpose test in the Multilateral Convention | OP 2141/2018/12 Intertax |
Resumen.
This article addresses the recent US tax reform's international provisions. Part II reviews the political context and time pressure under which the tax legislation was adopted, which explains why it was not a fundamental tax reform. Part III(A) reviews the most important "international" business provisions, starting with the pervasive effects of the reduction in the corporate tax rate and its interaction with credits for foreign income taxes. Part III(B) examines the new global intangible low-taxed income (GILTI) and foreign dividends received deduction provisions, the reduced effective tax rate for foreign derived intangible income (FDII) from exports and the base erosion alternative minimum tax or BEAT. Part IV comments on the most important international reform left unaddressed and Part V concludes.
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