The Resource Implementation of BEPS in the U.S

Implementation of BEPS in the U.S

Implementation of BEPS in the U.S
Implementation of BEPS in the U.S
This article describes the unique implications of the base erosion and profit shifting (BEPS) initiative to US taxpayers and the US tax authorities. American corporate groups have a particular global presence and they frequently play a leading role in the digital economy, which found special interest by BEPS. Another special aspect for the Americans is their current tax law, which avoids international double taxation by crediting (Foreign Tax Credit) instead of exemption. Hence, one concern of the US negotiation delegation was to assure a fair treatment of American corporate groups by BEPS. In general, the BEPS negotiations results satisfied the American delegation. Implementations in the U.S. tax law were primarily required and made regarding action item 13 (Country by Country Reporting). In other areas, the U.S. tax authorities' perception was that consisting or simultaneously occurring legislative amendments (e.g. tax deductibility of interest; IRC Section 385) were meeting the BEPS principles. The USA has not signed the Multilateral Agreement (action item 15) and, contemporarily, has no interest to do so in future
Citation source
In: Archiv für Schweizerisches Abgaberecht = Archives de droit fiscal suisse = Archivio di diritto fiscale svizzero. - Bern. - Vol. 86 (2017), no. 4 ; 229-242
Flick, H.F.W
Geographic coverage
North America
Language note
  • BEPS Project (OECD)
  • international tax planning
  • transfer pricing
  • intangibles
  • foreign tax credit
  • interest deduction
  • MLI
  • digital economy
  • inversion transaction
  • LoB
  • PE
  • arbitration
  • value creation
Implementation of BEPS in the U.S

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