Economic Analysis: Quantifying the Benefits of Profit Shifting Under GILTI, Part 2

Tax AnalystsBy Martin A. Sullivan

In economic analysis, Martin A. Sullivan examines the overall tax effect of a U.S. multinational shifting profit among its controlled foreign corporations and finds that, due to a quirk in the basic architecture of the Tax Cuts and Jobs Act rules, moving income from the high-tax jurisdiction to the low-tax jurisdiction is not always a tax minimizing strategy and may in fact backfire.

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By Martin A. Sullivan, posted on Wednesday August 21, 2019
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