Internet Platform Companies and Base Erosion—Issue and Solution

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Tax Notes

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Some provisions in the House and Senate versions of the Tax Cuts and Jobs Act close offending loopholes widely used by multinational companies, both U.S. and foreign, to shift profits outside the United States to minimize U.S. tax. As a measure of success, it has been widely reported that U.S. companies have parked more than $2.6 trillion offshore and outside the reach of the U.S. tax man. This has been done as the U.S. debt has ballooned to more than $20 trillion. Both of those numbers are staggering and hard to comprehend. So we must ask the following: Will these new provisions do the job, are they sufficient, and do they go far enough? A fair reading of the proposed changes suggests that the likely answer is no.

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