The Resource If not now, when? U.S. tax treaties with Latin America after TCJA

If not now, when? U.S. tax treaties with Latin America after TCJA

Label
If not now, when? U.S. tax treaties with Latin America after TCJA
Title
If not now, when? U.S. tax treaties with Latin America after TCJA
Creator
Subject
Language
eng
Summary
According to the author, there are three good reasons that Latin American countries should consider entering into tax treaties with the United States after the Tax Cuts and Jobs Act (TCJA). First, to the extent that the participation exemption applies, the result is better than tax sparing for countries that offer tax holidays. To the extent GILTI applies, there is still an incentive to invest in a tax holiday country because of cross-crediting, so that even with GILTI there may not be a revenue shift. Second, there are good reasons to enter into treaties even with a revenue shift, such as attracting FDI and limiting tax evasion. Third, Latin American countries are increasingly capital exporters, and the absence of a treaty hurts their multinationals. Finally, now is an opportunity, because the entire U.S. treaty network needs to be updated to take account of TCJA
Citation source
In: International tax journal. - Riverwoods. - Vol. 45 (2019), no. 4 (July-August) ; p. 57-59
http://library.link/vocab/creatorName
Avi-Yonah, R.S
Geographic coverage
  • North America
  • Latin America
Language note
English
http://library.link/vocab/subjectName
  • tax treaty
  • TCJA
  • MNE
  • GILTI
  • participation exemption
  • tax sparing credit
  • tax holiday
  • foreign investment
  • tax evasion
Label
If not now, when? U.S. tax treaties with Latin America after TCJA
Instantiates
Publication
Label
If not now, when? U.S. tax treaties with Latin America after TCJA
Publication

Library Locations

    • IBFD Library AmsterdamBorrow it
      Rietlandpark 301, Amsterdam, 1019 DW, NL
      52.3736660 4.9336932
Processing Feedback ...