Good Intentions, Bad Tools: A Case for Repealing the UTPR

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Good Intentions, Bad Tools: A Case for Repealing the UTPR

  • By Pramod Kumar Siva and William H. Byrnes

Pramod Kumar Siva and William H. Byrnes explain why the UTPR, formerly known as the undertaxed profits rule, is an unlawful extraterritorial tax that contravenes legal norms, generates economic distortions, and diminishes international tax cooperation.

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