Perspectives on Taxation Lecture Series
Expanded Worldwide versus Territorial Taxation After the TCJA
- Bob Peroni
Fondren Foundation Centennial Chair for Faculty ExcellenceUniversity of Texas School of Law
- Robert Kudrle
Orville and Jane Freeman Chair in International Trade and Investment PolicyUniversity of Minnesota Humphrey School of Public Affairs
Before the TCJA, US multinationals urged Congress to adopt a territorial or exemption system for foreign-source active business income, while labor-backed groups and others favored an expanded worldwide tax regime. With the TCJA, Congress chose both, creating a more complex international system that manages to include elements of territoriality, expanded worldwide taxation, and even deferral. Estimates suggest that the TCJA has shifted U.S. international taxation toward territoriality, but not nearly so much as territoriality advocates had hoped. Prof. Peroni will discuss the implications of the new regime as well as his conclusions that expanded worldwide taxation is the normatively preferred position and that the new GILTI approach may serve as a platform for moving in that direction.
One of the nation’s top international tax scholars, Professor Bob Peroni holds the Fondren Foundation Centennial Chair for Faculty Excellence at the University of Texas School of Law. He co-authors the three-volume treatise, U.S. International Taxation, and has written many articles and casebooks on international tax and other tax topics. He co-chairs the Annual Institute on Current Issues in International Taxation, co-sponsored by the IRS and George Washington University Law School. In 2000-01, he served as Academic Advisor to the Joint Committee on Taxation’s Study of the Overall State of the Federal Tax System. In 1985-86, he served as a Professor-in-Residence in the IRS’s Office of Chief Counsel. He also has taught at Tulane University, George Washington University, New York University, UCLA, the University of Pennsylvania, Northwestern University, and Georgetown University.
RSVP to Casey Kenney at (612) 626-5048 or firstname.lastname@example.org.
The University of Minnesota Law School Corporate Institute Forum on Taxation and Regulation
A buffet lunch will be served beginning at 12:00 p.m.