Abstract
The objective of this Article is to enter this policy debate by posing an effective section 482-based solution to the HI/BEPS problem that achieves each of the enumerated fiscal policy objectives. To formulate such a solution, the reasoning behind the HI/BEPS problem must be understood; thus, an analysis of the root cause of this phenomenon is set forth in Part III. In Part IV, we outline the various solutions to the HI/BEPS problem that have already been proposed. Finally, in Part V, we outline our proposed recommendation. It is our belief that policymakers, MNEs, and Congress all have a shared interest in finding a mutually acceptable solution to the HI/BEPS problem, yet no solution has garnered broad support.
Recommended Citation
Wells, Bret and Lowell, Cym
(2014)
"Tax Base Erosion: Reformation of Section 482's Arm's Length Standard,"
Florida Tax Review: Vol. 15:
No.
1, Article 12.
Available at:
https://scholarship.law.ufl.edu/ftr/vol15/iss1/12