Download This PaperIs the UTPR a 100 Percent Tax on a Deemed Distribution?
181 Tax Notes Federal 481 (2023) / 112 Tax Notes International 313 (2023)
7 Pages Posted: 5 Dec 2023
Date Written: October 16, 2023
Abstract
This article floats the proposition that from a U.S. tax perspective, the UTPR is the mathematical, conceptual, and legal equivalent of a 100 percent withholding tax on a deemed distribution by the UTPR entity, and addresses questions that would follow regarding the desirability of such a confiscatory tax and its interaction with tax treaties.
Keywords: UTPR, GloBE, Pillar 2, international tax, tax treaties
JEL Classification: K33, K34
Suggested Citation: Suggested Citation
Shaheen, Fadi, Is the UTPR a 100 Percent Tax on a Deemed Distribution? (October 16, 2023). 181 Tax Notes Federal 481 (2023) / 112 Tax Notes International 313 (2023), Rutgers Law School Research Paper, Available at SSRN: https://ssrn.com/abstract=4646253
Fadi Shaheen (Contact Author)
Rutgers, The State University of New Jersey - School of Law, Newark ( email )
Newark, NJ
United States
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