Omri MarianOmri Marian is a Professor of Law, and the Academic Director of the Graduate Tax Program at the University of California, Irvine (UCI) School of Law. Professor Marian is an expert in international taxation and comparative taxation. Before joining UCI, he was an assistant Professor of Law at the University of Florida where he taught in the graduate tax program. He also practiced as a tax associate in the New York office of Sullivan & Cromwell LLP. Professor Marian earned his LLM (International Taxation) and SJD from the University of Michigan Law School.
US International Anti-Avoidance Rules
The United States recently overhauled its international tax system, nominally moving from a worldwide to a territorial system. In reality, however, the new tax law is nuanced and extremely complex, incorporating both territorial and worldwide elements. In addition, the adoption of a participation exemption regime required U.S. Congress to adopt new anti-abuse rules, and to revamp certain existing anti-abuse rules, in order to prevent income shifting. The course will try to untangle some of these complexities, by exploring U.S. international tax anti-avoidance doctrines in light of the new law. We will discuss general US anti-avoidance policies as well the various particular mechanisms to fight both inbound and outbound tax avoidance, including CFC rules, LOB provisions, the new rules relating to Global Intangible Low-Taxed Income (GILTI), the new anti-mismatch rules, the new Base Erosion Anti-abuse Tax (BEAT), and anti-conduit financing rules.
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