THE CONSEQUENCES OF THE TAX CUT AND JOBS ACT’S INTERNATIONAL PROVISIONS

Abstract

This paper discusses the potential consequences of the international tax provisions of the recent Tax Cut and Jobs Act (TCJA), drawing on existing research. It uses the observed behavior of firms during the 2005 repatriation tax holiday to infer the relative burdens created by the repatriation tax and by the TCJA’s new “Global Intangible Low-Taxed Income” (GILTI) tax, and it concludes that the TCJA increases the tax burden on U.S. residence for many, and perhaps most, U.S. firms. It also argues that the GILTI and “Foreign-Derived Intangible Income” (FDII) provisions will create substantial distortions to the ownership of assets, both in the United States and around the world.

Cite this work

No public copy is stored for this record, so only the metadata is cited.

Stored only when both papers are in the corpus — 38 citations exist upstream.

Papers that cite the same references — the relational fallback while embeddings are still backfilling.