Internet Platform Companies and Base Erosion — Issue and Solution

7 Pages Posted: 9 Jan 2018  

David Koontz

Independent

Jeffery M. Kadet

University of Washington - School of Law

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

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

David Koontz

Independent ( email )

No Address Available

Jeffery M. Kadet (Contact Author)

University of Washington - School of Law ( email )

William H. Gates Hall
Box 353020
Seattle, WA 98105-3020
United States

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