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.
Avi-Yonah, Reuven S. "Is GILTI Constitutional?" TaxNotes Federal 170, no. 2 (2021): 283-287.
Available for download on Wednesday, January 08, 2031