Tuesday, October 6, 2020
J. Clifton Fleming (BYU) presents Worldwide vs. Territorial Taxation: The State of the Conflict in the United States virtually today at the Institute for Austrian and International Tax Law of the Vienna University of Economics and Business:
This paper is an extension of J. Clifton Fleming (BYU), Robert J. Peroni (Texas) & Stephen E. Shay (Boston College), Expanded Worldwide Versus Territorial Taxation after the TCJA, 161 Tax Notes 1178 (Dec. 3, 2018). It explains that on an overall basis, the TCJA did not accomplish a meaningful movement in the direction of either worldwide or territorial taxation although it rearranged the U.S. international income tax system in complex ways that necessitate new tax planning strategies. Possibilities for movement, as well as current developments, are examined and the conclusion is reached that it continues to be difficult to determine which way the U.S. is going.