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.
Law and Economics | Tax Law
Date of this Version
Working Paper Citation
Avi-Yonah, Reuven S., "Is GILTI Constitutional?" (2021). Law & Economics Working Papers. 204.