Thursday, May 24, 2018

Forthcoming article on U.S. international tax law

I have on a couple of occasions mentioned here the tax article that I've been working on, when time permits, since late January.  Entitled The New Non-Territorial U.S. International Tax System, it discusses and evaluates three of the main new international tax provisions in the 2017 tax act: the BEAT, GILTI, and FDII.  (This includes attempting to explain, very simply and intuitively rather than technically, what these provisions appear mainly to be "about.")

I have now completed the piece, and it will be appearing in Tax Notes in two parts, on July 2 and 9.

The two-part publication was necessary due to its length (close to 30,000 words), and made sense due to a natural breakpoint between the two main parts.  The first half focuses on international tax policy conundrums and dilemmas in general, and the second half on the BEAT, GILTI, and FDII in particular.

I put both halves of the analysis in the same article due to their complementarity. One needs the first part in order to ground the evaluation in the second part.  And I think the second part helps show that the normative discussion in the first part is focusing on things that countries actually care about - which cannot comparably be said about standard-fare generalizations regarding, for example, the supposedly central choice between "worldwide" and "territorial" models, neither of which any major industrial country appears to want in its unalloyed entirety.

While I don't pull my punches in evaluating the BEAT, GILTI, and FDII, the piece is written in a far kinder, more tolerant, and even verging on forgiving, spirit than my piece on the passthrough deduction. I expressly address in the new piece my reasons for taking a different tone here.  I also offer general thoughts regarding how the provisions might be changed or improved, taking the more defensible underlying policy aims as given, albeit without getting into the weeds as some outstanding recent pieces, such as this one, have.

On July 23, with Tax Notes' permission, I will be posting the article on SSRN. Evidently I'm fine with losing a few downloads under the official count, in exchange for having, I hope, significantly more actual readers.

I'll also be discussing the piece in Vienna on June 13, in Oxford at the end of June, in Ann Arbor on October 24, and in Copenhagen on November 5. (Time permitting, I'd be happy to add, say, Australia, New Zealand, China, or Japan to the tour, assuming roundtrip business class tickets, but no one has as yet asked.)

29 comments:

Anonymous said...
This comment has been removed by a blog administrator.
ProEssays said...

Some nice essays here - https://proessays.net/.

Unknown said...

Welcome to AVANT LOANS, Do you need a genuine loan Online to secure your Bills? Starts a new business? Do you need a personal loan? or Business loan, Apply for a quick and convenient loan to start a new financing of your projects at a cheapest interest rate of 2%. Are you in need of a Loan of any amount? Has the bank or Payday Loan Company refused your Loan Application because of your Low Credit Scores or Lack of Collateral Security? and you are in an urgent need of this Personal Or Business Loan to re-finance your business, pay your bills, settle your bad credit problems, buy and own a house of your own? etc. CONTACT US NOW VIA EMAIL:{ avantloan@yahoo.com }}}}}}

Avant Loans is the first lending platform to leverage artificial intelligence and machine learning to price credit and automate the borrowing process. Avant has demonstrated strong credit performance and maintains one of the industry’s highest consumer ratings according to leading consumer review sites. Apply for any kind of loan and any amount of your choice today by reaching us through email: { avantloan@yahoo.com }

Avant Loans believe Everyone deserves a better financial future if they strive for it. We’ve built a marketplace that keeps costs low and opportunity high.

You can also reach us via our website but for instant reply fill in the application form below and forward to our email address { avantloan@yahoo.com }

* Full Name:
* Loan amount needed:
* Loan Duration:
* Purpose of loan:
* City / Country:
* Telephone no:
* How Did You Hear About Us:

Genuinely Interested to get a loan then kindly email us { avantloan@yahoo.com } with the loan requirement above.

Sincerely yours,
Etienne L. Audrey
Company: Avant Loans
Contact: avantloan@yahoo.com

Unknown said...

★HIRE A LEGIT HACKER★

๐Ÿ”๐Ÿ”Are you Seeking for the Best Legit Professional Hackers online??❓๐Ÿ’ป๐Ÿ’ป๐Ÿ’ป
Congratulations Your search ends right here with us. ๐Ÿ”๐Ÿ”๐Ÿ”๐Ÿ”

๐Ÿ…COMPOSITE HACKS is a vibrant squad of dedicated online hackers maintaining the highest standards and unparalleled professionalism in every aspect.
We Are One Of The Leading Hack Teams in The United States๐Ÿ‡บ๐Ÿ‡ธ๐Ÿ‡บ๐Ÿ‡ธ With So many Accolades From The IT Companies๐Ÿ†๐Ÿ…๐Ÿฅ‡. In this online world there is no Electronic Device we cannot hack. Having years of experience in serving Clients with Professional Hacking services, we have mastered them all. You might get scammed for wrong hacking services or by fake hackers on the Internet. Don't get fooled by scamers that are advertising false professional hacking services via False Testimonies, and sort of Fake Write Ups.❌❌
COMPOSITE HACKS is the Answers to your Prayers

* OUR HACKING CAPABILITIES:
We Offer Varieties Of LEGIT Hacking Services With the Help Of Our Root HackTools, Special HackTools and Our Technical Hacking Strategies Which Surpasses All Other Hackers.
We Can help you Hack Or recover the password of any email, Facebook or any other Social Media accounts, Phone Hack (Which enables you to monitor your kids/wife/husband/boyfriend/girlfriend, by gaining access to everything they are doing on their phone without their notice), You Wanna Hack A Website or Database? You wanna Clear your Criminal Records?? Location Tracking? Our Team accepts all types of hacking orders and delivers assured results to alleviate your agonies and anxieties.

* SOME OTHER SPECIAL SERVICES WE OFFER INCLUDES:
★ Bank Accounts Loading ( Only USA & UK Banks)
★ Credit Cards Loading (Only USA & UK CC's)
★ Money Flipping
★ Bitcoin Mining ⛏

๐Ÿ…We have a trained team of seasoned professionals under various skillsets when it comes to online hacking services. Our company in fact houses a separate group of specialists who are productively focussed and established authorities in different platforms. They hail from a proven track record Called “HackerOne” and have cracked even the toughest of barriers to intrude and capture or recapture all relevant data needed by our Clients. Some Of These Specialists Includes ⭐️ PETER YAWORSKI⭐️ FRANS ROSEN ⭐️JACK CABLE ⭐️ JOBERT ABMA ⭐️ ARNE SWINNEN ⭐️ And More

๐Ÿ… COMPOSITE HACKS understands your requirements to hire a professional hacker and can perceive what actually threatens you and risk your business⚔️, relationships or even life๐Ÿ‘Œ๐Ÿฝ. We are 100% trusted professional hacking Organization and keep your deal entirely confidential๐Ÿ’ฏ. We are aware of the hazards involved. Our team under no circumstances disclose information to any third party❌❌. The core values adhered by our firm is based on trust and faith. Our expert hacking online Organization supports you on time and reply to any query related to the unique services we offer
Time also depends on what exactly you want to hack and how serious you are. Enough time with social engineering is required for hacking. So if you want to bind us in a short time, then just DONT contact us because we can't hack within 10-15minutes, *sorry*.
I have seen FAKE HACKERS claiming they can hack in 10min , but there is no REAL HACKER who can say this (AVOID THEM) ๐Ÿ’ฏ

๐Ÿ…COMPOSITE HACKS is available for customer care 24/7, all day and night. We understand that your request might be urgent, so we have a separate team of allocated hackers who interact with our Clients round the clock⏰. You are with the right people so just get started.๐Ÿ’ฏ✅

๐Ÿ“ฒ CONTACT:
E-mail: compositehacks@gmail.com
Hire a Hacker!
Want faster service? Contact us!
HackerOne©️LLC 2018.
All Rights Reserved ®️

★We Treat Every Request With Utmost Confidentiality★ ๐Ÿ™Œ๐Ÿฝ

Ahmed89 said...

o you need a quick long or short term loan with a relatively low interest rate as low as 3%? We offer business loan, personal loan, home loan, auto loan,student loan, debt consolidation loan e.t.c. no matter your credit score. We are guaranteed in giving out financial services to our numerous clients all over world. With our flexible lending packages, loans can be processed and transferred to the borrower within the shortest time possible, contact our specialist for advice and finance planning. If you need a quick loan contact us via Email: ahmedconsultancycompany@gmail.com

Ahmed89 said...


Are you searching for a very Genuine Loan? The good news is here ! ! ! We Offer LOANS ranging from $5000.00 to $5, 000, 000.00Max. at 3% interest rate per annual. LOANS for developing business We are certified, trustworthy,? reliable, efficient, Fast and dynamic.contact? us
ahmedconsultancycompany@gmail.com
Borrowers Information Needed Fill And Return.
Full Names:.........................
Contact Address:..................
Country:........................
Amount Needed:.......
Loan Duration:..............
Purpose Of Loan:.......
Occupation:..........
Sex:..........
Age:...........
Phone Number:..........
Marital Status:...........
Best Wishes,

ahmedconsultancycompany@gmail.com

Ahmed89 said...

Do you need Finance?
Are you looking for Finance?
Are you looking for a money to enlarge your business?
We help individuals and companies to obtain loan for business
expanding and to setup a new business ranging any amount. Get a loan at affordable interest rate of 3%, Do you need this cash/loan for business and to clear your bills? Then send us an email now for more information contact us now via Email:ahmedconsultancycompany@gmail.com

Unknown said...

there have said to create a superb article like this is great thing. I’ll learn many new stuff right here. really useful Forthcoming article on U.S. international tax law to introduce.





Pay less tax in the UK

Property tax planning in the UK

Michel starc said...

Online sex shop
Buy 100% legal imported adult Sex Toys for Men & Women . We are leading Adult Sex Products Online Store. Buy cock ring for Men, Vibrators, dildos for Female, strap-ons, masturbators, fleshlights etc!

Unknown said...

Do you need an urgent loan today? Are you thinking of clearing debt or you have intentions of starting a new business? We offer loans at low interest of 3% for personal and business purposes! We also offer easy approval and fast transfer as guaranteed by our insurance company. Interested persons should contact Mr Thomas with Email: Thomasrivera101@outlook.com or Call Phone: +1-(631)-542-4685

Anonymous said...

Nice post thanks for sharing.
We at Instant credit loans provide these Loans for people with bad credit with reasonable interest rates. ?Instant approval ?No Collateral ?No Hassel.

https://www.instantcreditloansus.com/

Mr. Hussein Mohamed said...

Do you need long or short term first class financial offer of different categories such as business, personal, home, auto, student, debt consolidation finance e.t.c. no matter your credit score. We are guaranteed in giving out financial services to our numerous clients all over world. With our flexible lending packages, funds can be processed and transferred to the borrower within the shortest time possible, contact our specialist for advice and finance planning through the E-mail: trivagofinancialhome.in@gmail.com call/WhatsApp us +1(315) 285-7649 website https://trivagofinance.wixsite.com/home for easy application.

Mr. Hussein Mohamed said...

Are you tired of seeking loans and Mortgages,have you been turned down constantly By your banks and other financial institutions, We offer any form of loan to individuals and corporate bodies at low interest rate.If you are interested in taking a loan,feel free to contact us today,we promise to offer you the best services ever.Just give us a try,because a trial will convince you.What are your Financial needs?Do you need a business loan?Do you need a personal loan?Do you want to buy a car?Do you want to refinance? Do you need a mortgage loan?Do you need a huge capital to start off your business proposal or expansion? Have you lost hope and you think there is no way out, and your financial burdens still persists? You will be sent the company loan terms and condition immediately.Be assured that your loan application will be handled with privacy and in a professional manner and you will receive a prompt answer to your request.

NAME OF APPLICANT:_________________________
RESIDENTIAL COUNTRY:______________________
RESIDENTIAL ADDRESS:______________________
BUSINESS ADDRESS:_________________________
AGE:_________________________
OCCUPATION:_________________________
AMOUNT OF LOAN REQUIRED:__________________
Loan Duration:_________________________
PURPOSE OF THE LOAN:_______________________
Phone NUMBER:_________________________
LOAN DURATION:_________________________

Once we are in receipt of this information,You will be sent the company loan terms and condition immediately.Be assured that your loan application will be handled with privacy and in a professional manner and you will receive a prompt answer to your request. Email: trivagofinancialhome.in@gmail.com call/WhatsApp us +1(315) 285-7649 website https://trivagofinance.wixsite.com/homee for easy application.

max william said...

Do you need Finance?
Are you looking for Finance?
Are you looking for a money to enlarge your business?
We help individuals and companies to obtain loan for business
expanding and to setup a new business ranging any amount. Get a loan at affordable interest rate of 3%, Do you need this cash/loan for business and to clear your bills? Then send us an email now for more information contact us now via Email:maxcreditfinance@googlemail.com

Kavita Pheerangee said...



PLEASE READ!!!! PLEASE READ!!!! PLEASE READ!!!! PLEASE READ!!!!

Hey Guys!!!Am so happy I got my blank ATM card can withdraw € 2,000 daily. I got it from Her last week and now I have €14,000 . The blank ATM withdraws money from any ATM machines and there is no name on it, it is not traceable and now i have money for business and enough money for me and my family to live on . I am really happy i met him because i met two people before her and they took my money not knowing that they were scams. But am happy now. He sent the card through DHL and i got it in two days. Get your own card from her now she is not like other scammer pretending to have the ATM card, She is giving it out for to help people even if it is illegal but it helps a lot and no one ever gets caught. i'm grateful to him because he changed my story all of a sudden . The card works in all countries except, Mali and Nigeria. His email address is : int.hackers002@gmail.com

asda services said...

Blank ATM Cards
Do you know that you can withdraw cash from any ATM machine !!!

We have specially programmed ATM cards that can be used to used to withdraw cash at the ATM or swipe, stores and outlets. We sell this cards to all our customers and interested buyers worldwide, the cards has a daily withdrawal limit of € 5000 in ATM and up to € 100,000 spending limit in it stores.
The blank ATM withdraws money from any ATM machines and there is no name on it because it is blank just your PIN will be on it, it is not traceable.PROGRAMMED blank ATM card works on any card supported machine,anywhere in the world.
Contact Person: Prof Alexander Castro
E-Mail: atmservices44@aol.com
hacklords.investors@gmail.com
whatsapp +17042750147

Unknown said...

Need a Debt Loan To Pay Off Bills?
Take control of your debt today
Available Now Business Expansion Loan Offer?
Do you need a loan to pay off Bills?
Do you need a loan?
Do you need Personal Loan?
Business Expansion Loan?
Business Start-up, Education,
Debt Consolidation Loan
Hard Money Loans
Loan for any thing ?
We offer loan at low interest rate of 4%
Loan with no credit check,
Email us: markthomasfinanceltd@gmail.com

Whats-App no +919667837169
Dr. Mark Thomas

Unknown said...

We provide personal loans for debt consolidation, bad credit loans
*Commercial Loans.
*Personal Loans.
*Business Loans.
*Investments Loans.
*Development Loans.
*Acquisition Loans .
*Construction loans.
*Business Loans And many More:

Contact us with our valid email: markthomasfinanceltd@gmail.com

Calling/Whats App +919667837169
Mr. Mark Thomas

Ki su Son said...


We have a direct genuine provider for BG/SBLC specifically for lease, at leasing price of 4+2 of face value, Issuance by HSBC London/Hong Kong or any other AA rated Bank in Europe, Middle East or USA.

Contact : Mr. DARREN C CHENG
Email: Darrencraig002@gmail.com
skype : keatcheng2@gmail.com

Intermediaries/Consultants/Brokers are welcome to bring their clients and are 100% protected. In complete confidence, we will work together for the benefits of all parties involved.

All inquires to Mr. Darren should include the following minimum information so I can quickly address your needs:

Complete contact information:
What exactly do you need?
How long do you need it for?
Are you a principal borrower or a broker?

Contact me for more details.

Whatsapp: +19733700521

Standard Online Finance said...

We currently have funds for Financing Real Estate, Project Funding, Bridge Loans, Construction Financing, and Ordinary Loans for Company Export/Import financing projects of large volume.

Our funding interest rate is 3% with five months grace period, and the client needs to ensure his/her project with an insurance company of the total loan sum to guarantee the loan as collateral.

E-Mail us: standardonlineinvestment@gmail.com

Loan lender said...

Are you in need of Urgent Loan Here no collateral required all problem regarding Loan is solve between a short period of time with a low interest rate of 2% and duration more than 20 years what are you waiting for apply now and solve your problem or start a business with Loan paying of various bills You have come to the right place just contact us abdullahibrahimlender@gmail.com
whatspp Number +918929490461
Mr Abdullah Ibrahim

Anonymous said...

Thank you for sharing this useful material. The information you have mentioned here will be useful. I would like to share with you all one useful source https://mid-terms.com/statistics-research-projects/ which might be interesting for you as well.

Anonymous said...

I use hire nursing writer. This is an important place for every student. If I need to write an essay I know I can get everything there on any topic. This is very important to me.

About Us said...


really infomative and eduvcative article thanks publisher for sharing this info with us zero gravity massage chair>

Anonymous said...

In general, I liked the service of the essay professor company, the good attitude of the staff. It seems to me that this is a company where the price-quality ratio corresponds to reality. Of course, I will still contact them!

robertcooper said...

Hello. I am very happy to be able to get extra help. I started using this custom writing services https://elitewritings.com/. I am glad to have a place where I can always buy everything for my studies. Have a nice day!

Unknown said...

I am Rachael, I am posting this voluntarily because I was glad to get my loan after I was deceived. I was in need of a loan to pay my debt and i was seeking for a legit loan company that could help me with a loan of $ 450 thousand dollars but i was decline of getting the amount i needed and along the line i was introduced to a private loan lender Mr. Fredrick Burkhart which i tried my best to give a try and i was asked to come and pay a fee which i refused because i was scared to be scammed for the second time because of my bad experience i had by trying to get this very important loan to pay my debt but Mr. Fredrick Burkhart gave me his word of advice and told me I am in the right place to get a loan and I was lucky for the loan I applied for. contact via aol mail. (guarantycreditunion6692@aol.com)

Snehal pnade said...

Thanks for sharing informative article, Keep sharing with us!
Personal loan online

Outbooks Australia said...

Accounts Payable (AP) is one of the most challenging tasks for businesses to perform in today's competitive environment.