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U.S. Skeptical About Permanent Safe Harbor for GLOBE Tax Framework

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The U.S. Tax System’s Curious Embrace of Manufacturing Job Losses

  • By J. Clifton Fleming Jr., Robert J. Peroni, and Stephen E. Shay

J. Clifton Fleming Jr., Robert J. Peroni, and Stephen E. Shay explain how the subpart F regime and the global intangible low-taxed income regime together contribute to a long-running decline in domestic manufacturing employment, and they argue that the best approach to fixing the problem is worldwide taxation without deferral, not pillar 2.

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