Pillar 2 and the Corporate AMT

TAX NOTES INTERNATIONAL, VOLUME 107, AUGUST 8, 2022

U of Michigan Public Law Research Paper Forthcoming

5 Pages Posted: 20 Jan 2023

See all articles by Reuven S. Avi-Yonah

Reuven S. Avi-Yonah

University of Michigan Law School

Bret Wells

University of Houston Law Center

Date Written: August 8, 2022

Abstract

This article argues that the corporate alternative minimum tax enacted as part of the Inflation Reduction Act of 2022 puts the United States in a better position than current law, and arguably even better than would a tax reform package that included a conforming global intangible low-taxed income regime but no book-based corporate minimum tax.

Keywords: Pillar 2, Pillar Two, GloBE, Corporate Alternative Minimum Tax

JEL Classification: K34

Suggested Citation

Avi-Yonah, Reuven S. and Wells, Bret, Pillar 2 and the Corporate AMT (August 8, 2022). TAX NOTES INTERNATIONAL, VOLUME 107, AUGUST 8, 2022 , U of Michigan Public Law Research Paper Forthcoming, Available at SSRN: https://ssrn.com/abstract=4328870

Reuven S. Avi-Yonah

University of Michigan Law School ( email )

625 South State Street
Ann Arbor, MI 48109-1215
United States
734-647-4033 (Phone)

Bret Wells (Contact Author)

University of Houston Law Center ( email )

4604 Calhoun Road
4604 Calhoun Road
Houston, TX 77204-6060
United States

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