TaxProf Blog

Editor: Paul L. Caron, Dean
Pepperdine University School of Law

Wednesday, October 3, 2018

Clausing Presents Profit Shifting Before And After The TCJA Today At Pennsylvania

Clausing (2017)Kimberly Clausing (Reed College) presents Profit Shifting Before and After the TCJA at Pennsylvania today as part of its Tax Law and Policy Workshop Series hosted by Michael Knoll, Chris Sanchirico, and Reed Shuldiner:

In recent years, estimates of profit shifting by multinational companies have indicated substantial revenue costs to the U.S. government, likely in excess of $100 billion per year. The TCJA has changed the climate for profit shifting in several important ways: the lower U.S. corporate rate should lower the incentive to shift profits away from the United States, the adoption of a territorial tax system should raise the incentive to shift profits abroad, and several novel base protection measures, in particular the GILTI and BEAT provisions, are aimed directly at profit shifting. This paper evaluates these changes, discussing their likely effect on the magnitude of profit shifting.

Estimates suggest that the legislation should reduce the corporate tax base in haven countries by about $95 billion, increasing the tax base in both the United States and in higher-tax foreign countries. Still, positive U.S. tax revenue effects are likely to be modest due to the design of the provisions.

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