Internet Platform Companies and Base Erosion — Issue and Solution
7 Pages Posted: 9 Jan 2018
Date Written: December 4, 2017
Abstract
By measuring base erosion only through certain related party outbound payments, the Tax Cuts and Jobs Act misses much of the profit shifting that has created the more than $2.6 trillion of overseas untaxed profits. This article shows how the base erosion provisions in the legislation could be easily expanded to make them truly effective and a real disincentive to continued profit shifting.
Keywords: Tax Reform, Profit-Shifting, Effectively Connected Income, ECI, International Taxation
JEL Classification: H21, H25, K34, E62
Suggested Citation: Suggested Citation
Koontz, David and Kadet, Jeffery M., Internet Platform Companies and Base Erosion — Issue and Solution (December 4, 2017). Tax Notes, Vol. 157, No. 10, December 2017, Available at SSRN: https://ssrn.com/abstract=3096925
Do you have a job opening that you would like to promote on SSRN?
Feedback
Feedback to SSRN
If you need immediate assistance, call 877-SSRNHelp (877 777 6435) in the United States, or +1 212 448 2500 outside of the United States, 8:30AM to 6:00PM U.S. Eastern, Monday - Friday.