Tax Planning Under the Destination Based Cash Flow Tax: A Guide for Policymakers and Practitioners
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How to Cite

Miller, D. S. (2017). Tax Planning Under the Destination Based Cash Flow Tax: A Guide for Policymakers and Practitioners. Columbia Journal of Tax Law, 8(2), 295–308. https://doi.org/10.7916/cjtl.v8i2.2852

Abstract

This essay describes some basic tax-planning strategies under the destination based cash flow tax (DBCFT) proposed as part of the “Blueprint” published by the Committee on Ways & Means of the House of Representatives. This article is designed first for policymakers so that they can either correct or confirm the strategies I describe, and second for the practitioners and taxpayers that will navigate the DBCFT if it is enacted.

A central theme of the discussion that follows is that the DBCFT contained in the Blueprint is not the “pure” DBCFT proposed by economists. Instead, it is a hybrid that incorporates aspects of the pure DBCFT, but also elements of our current income tax.  Many of the planning opportunities under the DBCFT arise because of its hybrid nature.

https://doi.org/10.7916/cjtl.v8i2.2852
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