The New Non-Territorial U.S. International Tax System, Part 1

Abstract

This paper, published in Tax Notes on July 2, 2018, is the first half of a two-part paper examining and analyzing the three main international provisions in the 2017 tax act. Part 1, contained herein, discusses normative frameworks for international tax policy. Part 2 will focus on the base erosion and anti-abuse tax (the BEAT), global intangible low-taxed income (GILTI), and foreign-derived intangible income (FDII).

Keywords: international tax policy, Tax Cuts and Jobs Act, GILTI, BEAT, FDII

JEL Classification: H20, H25