Surveying the evolution of international taxation, exploring the impact of source and residence taxation on subpart F, proposing a modified GILTI aligned with Pillar Two, advocating for a streamlined residence-based tax system, and recommending restrictions on subpart F to focus on passive income an

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This data presents a comparison of rolling conformity jurisdictions addressing GILTI provisions under the 2017 Tax Cuts and Jobs Act. It outlines the jurisdictions coupled with provisions, including levels of GILTI incorporation. Additionally, it offers insights into projected effects on corporate i

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