Is GILTI Constitutional?

6 Pages Posted: 12 Mar 2021 Last revised: 24 Jun 2021

Date Written: February 6, 2021


In this article, Avi-Yonah argues that the global intangible low-taxed income regime may be an unconstitutional attempt to tax the foreign-source income of foreign entities, and he offers an alternative.

Keywords: GILTI, constitutionality

JEL Classification: H26

Suggested Citation

Avi-Yonah, Reuven S., Is GILTI Constitutional? (February 6, 2021). Tax Notes Federal, January 11, 2021, p. 283, U of Michigan Law & Econ Research Paper No. 21-018, U of Michigan Public Law Research Paper No. 21-018, Available at SSRN:

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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