Australia has received considerable attention as a result of its unilateral actions to discourage multinational profit shifting. Those actions include the 2015 enactment of the Multinational Anti-Avoidance Law and the Australian Treasury's May 2016 proposal for a diverted profits tax. This...

By measuring base erosion only through certain related party outbound payments, the Tax Cuts and Jobs Act misses much of the profit shifting that has created the more than $2.6 trillion of overseas untaxed profits. This article shows how the base erosion provisions in the legislation could be...

In regard to "Options to address the broader direct tax policy challenges", I suggest that the Task Force consider several matters:- Practical "best practice" approaches for determining some minimal level of digital presence that would be treated as a PE. The Task Force should recommend language...