US International Corporate Taxation after the Tax Cuts and Jobs Act
Why this work is in the frame
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Bibliographic record
Abstract
The root dilemma that informs the past, present, and future of US international taxation is the tension between two desiderata: protecting the corporate tax base from erosion and ensuring the competitiveness of US multinational firms in the world economy. This article begins by exploring that tension, discussing the evidence behind these competing policy goals. It then considers the international tax provisions of the Tax Cuts and Jobs Act of 2017. TCJA enacted transformative changes in US corporate tax policy, but it did not resolve long held policy concerns. While research on TCJA is in early stages, evidence indicates that TCJA substantially reduced corporate tax revenues, that TCJA’s international provisions (as a whole) raised less revenue than expected, that offshoring and profit shifting remain large policy concerns, that changes in US multinational company competitiveness were mixed, and that underlying trends in wages and investment did not change due to TCJA. While TCJA was unable to resolve the tension between competitiveness and tax base protection, the Pillar 2 international tax agreement shows more promise in that regard. As countries throughout the world implement a “country-by-country” minimum tax on multinational income of 15 percent, this has the potential to disrupt long-standing arguments about international corporate taxation.
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Full frame distilled prediction
Teacher imitationNot calibrated prevalence, not ground truth. Human validation pending. Learned from the 10,348 direct Codex labels and 10,348 direct Gemma labels. Candidate is the union of thresholded teacher heads; consensus is their intersection. These outputs are machine_predicted_unvalidated and are not human labels or direct frontier model labels.
Codex and Gemma teacher scores by category
| Category | Codex | Gemma |
|---|---|---|
| Metaresearch | 0.001 | 0.000 |
| Meta-epidemiology (narrow) | 0.000 | 0.000 |
| Meta-epidemiology (broad) | 0.000 | 0.000 |
| Bibliometrics | 0.000 | 0.000 |
| Science and technology studies | 0.000 | 0.000 |
| Scholarly communication | 0.000 | 0.001 |
| Open science | 0.000 | 0.000 |
| Research integrity | 0.000 | 0.000 |
| Insufficient payload (model declined to judge) | 0.000 | 0.000 |
Machine scores (provisional)
The two teacher heads of the student model, read on this work. A score orders the frame for review; it never asserts a category, and the validation status ships verbatim with every row.
Baseline scores from an immature model (maturity gate not passed, 7 training rounds). Scores rank; they never assert a category.
score_only:v0-immature-baseline · verbatim from the scoring run: score_only means the number may rank works, and no category label ships from it