New article idea

I agreed a couple of months ago to give a talk in Finland on June 1, at the 2017 Annual Conference of the Nordic Tax Research Council. It was planned at the time that I would address the Ryan tax reform plan – meaning in particular the destination-based cash flow tax (DBCFT) – for my northern European audience that can only watch U.S. developments from afar. I’m also committed to write a very short paper for the Nordic Tax Journal based on the talk.

The DBCFT is of course an interesting topic, and for the above purposes I thought I could reasonably be a consumer in writing the talk, and purveyor to my audience in delivering the talk and paper, of the best work that’s been done in the U.S. (by a number of excellent people) analyzing the issues that it raises. But I also knew that the DBCFT might have collapsed politically by the time of the talk, and figured that, under that seemingly likely scenario, I’d need a backup plan. This would have the potential, however, to make the talk more fun and interesting for me, by reason of its putting me in a position to contribute more of my own particular thoughts (as opposed to mainly reporting about others’ work).

I think we’re now at that point. While it’s dangerous to base one’s ongoing work on assumptions regarding what’s going to happen in Washington, it certainly does appear to be the case that the enactment of a destination-based corporate tax appears is dead in the U.S., at least for the time being.

But it’s an interesting question why this thing, which is so different, at least formally, from what everyone else in the world does, should have risen to such prominence before its apparent political collapse. This isn’t a criticism of the DBCFT or its proponents – rather, it’s a point about the peculiarity of U.S. taxation and tax politics, such that we’re the only OECD country without a VAT, our corporate income tax statutory rate is unusually high, etc. It’s because things are so peculiar here that the policy aims underlying the proposal took this particular form. And that’s worth laying out a bit, in ways that will be more familiar going in to Americans than others, but even for Americans perhaps illuminating to explore.

So here’s my current working title: “The Rise and Fall of the DBCFT: What Was That About?” There might be enough content here to support, not just my talk in Finland on June 1 and short paper in a journal that few Americans will read, but also more extensive U.S. development and dissemination of.the main themes.