The Triumph of BEPS: US Tax Reform and the Single Tax Principle

9 Pages Posted: 7 Dec 2017 Last revised: 27 Dec 2017

Date Written: December 2, 2017


The Tax Cut and Jobs Act (TRA17) as passed by the House on November 16 and by the Senate on December 2, 2017, contains multiple provisions that incorporate the principles of the OECD/G20 Base Erosion and Profit Shifting (BEPS) into domestic US tax law. Together with the changes in the 2016 model US tax treaty, these provisions mean that the US is following the EU and China in implementing BEPS and in particular its underlying principle, the single tax principle (i.e., all income should be subject to tax once: passive income at the residence state rate and active income at a minimum source tax rate). This represents a triumph for the G20/OECD and is incongruent with the generally held view that the US will never adopt BEPS.

Keywords: tax reform, beps

JEL Classification: H26

Suggested Citation

Avi-Yonah, Reuven S., The Triumph of BEPS: US Tax Reform and the Single Tax Principle (December 2, 2017). U of Michigan Public Law Research Paper No. 579, U of Michigan Law & Econ Research Paper No. 17-021, Available at SSRN: or

Reuven S. Avi-Yonah (Contact Author)

University of Michigan Law School ( email )

625 South State Street
Ann Arbor, MI 48109-1215
United States
734-647-4033 (Phone)

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