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The US response to the final BEPS report

Karl Kellar and Lori Hellkamp (Jones Day, Washington, USA) review the US response to the BEPS report.
 

The United States’ response to the BEPS 2015 final report released on 5 October varies depending on whom one asks: Congress the Administration or the private sector. Broadly speaking representatives from both branches of government have been of the BEPS process. This presumably stems from a general impression that the BEPS initiative originated at least in part from the desire of foreign governments to capture more tax revenue from US-based multinationals. Some legislators are openly hostile. US Treasury representatives are more cautious in their criticisms not wanting to openly oppose the developing international consensus and wanting to retain a seat at the table as new norms of global taxation evolve.

The Treasury believes that in general the current US rules are consistent with many of...

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