Constructive Dialogue: BEPS and the TCJA

23 Pages Posted: 20 Mar 2020 Last revised: 18 May 2020

Date Written: February 24, 2020


US international tax law is commonly conceived as developed in the US and influencing the development of other countries' international tax law. This paper will argue that in the case of the TCJA, the US legislation was heavily influenced by the OECD BEPS project, and that the continuing OECD work in Pillars I and II is likely to have a similar influence on the future development of US international tax law.

Keywords: BEPS, TCJA

JEL Classification: H26

Suggested Citation

Avi-Yonah, Reuven S., Constructive Dialogue: BEPS and the TCJA (February 24, 2020). U of Michigan Public Law Research Paper No. 665, U of Michigan Law & Econ Research Paper No. 20-004, 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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