US international tax law is commonly conceived as developed in the US and influencing the development of other countries' international tax law. This paper will argue that in the case of the TCJA, the US legislation was heavily influenced by the OECD BEPS project, and that the continuing OECD work in Pillars I and II is likely to have a similar influence on the future development of US international tax law.
International Law | Law and Economics | Public Law and Legal Theory | Taxation-Transnational
Date of this Version
Working Paper Citation
Avi-Yonah, Reuven S., "Constructive Dialogue: BEPS and the TCJA" (2020). Law & Economics Working Papers. 168.