The Resource Proposed earnings stripping regs do not align with BEPS Action 4

Proposed earnings stripping regs do not align with BEPS Action 4

Label
Proposed earnings stripping regs do not align with BEPS Action 4
Title
Proposed earnings stripping regs do not align with BEPS Action 4
Creator
Subject
Language
eng
Summary
This article argues that the proposed IRC section 385 regulations on earnings stripping could conflict with the spirit of the best practices approach to limitations on interest deductions agreed in the OECD's final action 4 report. That report encourages multinational enterprises to spread their third-party debt load equitably among their affiliates worldwide so that no one country bears an unfair share of the debt burden and to mitigate risks of double taxation. The proposed regulations would make that practice impossible in many instances. The author recommends that the regulations be modified to allow U.S. subsidiaries of foreign MNEs to freely leverage up to at least the worldwide group's external debt level to facilitate achievement of the agreed base erosion and profit-shifting goal
Citation source
In: Tax notes international. - Falls Church. - Vol. 83 (2016), no. 3 ; p. 217-221
http://library.link/vocab/creatorName
Chamberlain, D.G
Geographic coverage
International
Language note
English
http://library.link/vocab/subjectName
  • OECD
  • BEPS Project (OECD)
  • earnings stripping
  • interest deduction
Label
Proposed earnings stripping regs do not align with BEPS Action 4
Instantiates
Publication
Label
Proposed earnings stripping regs do not align with BEPS Action 4
Publication

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