Paul L. Caron

Tuesday, January 4, 2022

Avi-Yonah: First Impressions Of the International Tax Provisions Of BBB: A Reasonable Compromise

Reuven Avi-Yonah (Michigan; Google Scholar), First Impressions of the International Tax Provisions of BBB: A Reasonable Compromise:

The recently unveiled international tax provisions of the Build Back Better Act (BBB) represent a reasonable compromise. They are consistent with the OECD’s Pillar Two statement, and they represent a significant move toward the implementation of the single tax principle (STP). In what follows, we will discuss the proposed changes and how they fit in with the new international tax regime.

The BBB international tax provisions, while flawed like any legislation that needs to get a majority vote in Congress, represent a reasonable compromise position. They implement Pillar Two and are a big improvement over the TCJA. They are likely to produce significant revenue and therefore help strengthen the US social safety net and combat climate change.

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