US Tax Reform: Potential Impact on Europe and EU Corporations (Presentation Slides)
Document Type
Article
Publication Date
2018
Abstract
Tax Cuts and Jobs Act (“TCJA”) signed into law by President Trump on 22 December 2017 contains multiple provisions that significantly impact Europe and the way European corporations are being taxed by the US. The US corporate tax rate is set to be 21% (reduced from 35%). Most importantly, the shift towards participation exemption and the adoption of the base erosion anti-abuse tax (“BEAT”), the global intangible low-taxed income (“GILTI”) and the foreign-derived intangible income (“FDII”) changed the delicate balance of US-EU taxation. Nonetheless, TCJA should not be considered as a ‘tax war’: it is a long-overdue response to the BEPS by US and a correct application of the single tax principle to prevent double non-taxation.
Recommended Citation
Avi-Yonah, Reuven S., "US Tax Reform: Potential Impact on Europe and EU Corporations (Presentation Slides)" (2018). Public Law & Legal Theory Working Papers. 249.
https://repository.law.umich.edu/pub_law_archive/249