OBBBAの続き、国際面、academic

さらに進めた。

ぼく：

what about academic

ChatGPT:

 Yes — there are academic-style resources you can tap to deepen your understanding of the international tax side of the One Big Beautiful Bill Act (OBBBA). They vary in degree of “peer-reviewed scholarly journal” vs working-paper format, but they’ll give you thoughtful theory, modelling, and critique rather than just practitioner how-to.

Here are some good ones + how I recommend you use them:

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✅ Good academic-style pieces on OBBBA & related international tax reform

• Brookings Institution: “When tax laws defy public opinion: What OBBBA reveals” — looks at how the law passed despite public opposition, discussing political economy and implications for tax legitimacy. (Brookings)

• Budget Lab at Yale University: “Long-term Impacts of the One Big Beautiful Bill Act” — includes macro-modelling of the law’s effects, useful for international spill-over thinking. (The Budget Lab at Yale)

• On more general international tax reform (not OBBBA-specific but strongly relevant): Profit Shifting and International Tax Reforms (Ferrari, Laffitte, Parenti & Toubal) — models how multinational profit shifting reacts to tax changes, which is very applicable to how OBBBA modifies regimes like GILTI/FDII. (arXiv)

• A working academic summary of the OBBBA: Understanding the Tax Provisions of the One Big Beautiful Bill Act (Donaldson) — outlines many of the key provisions including international ones. (SSRN)

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🔍 Why these help for international tax workstream

• They provide theory and modeling (not just “what changed”) — e.g., how profit-shifting might respond, how tax base erosion flows may change.

• They help position your planning advice in a broader context (global tax competition, treaty networks, BEPS/anti-avoidance) not just US-only detail.

• They help with risk-spotting: by showing what kinds of behavioural responses are plausible you can anticipate what models/structures you’ll need to stress-test.

• They help with commentary and publication if you or your firm want to write a thought-leadership piece.

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🧠 How to use them in practice

• Map theory → practice: Take a model result (e.g., the “elasticity of profit shifting” from the Ferrari et al work) and ask: how does the renamed/rewritten provisions in OBBBA (e.g., GILTI → “Net CFC Tested Income” etc) change that elasticity for US multinationals?

• Use as supporting references: When you deliver a memo to clients, cite the academic work to back up planning warnings (“the literature suggests home-jurisdiction tax reform triggers profit-shifting increases of X%…”).

• Identify gaps: The academic literature may not yet fully cover the new OBBBA international provisions (because the law is so recent). So you’ll want to flag “area needing further study” (e.g., how treaty networks will adjust to FDDEI changes) — and your client memo can note “we are working in area of limited empirical precedent”.

• Stay alert for new working papers: Because OBBBA is very recent, many “academic” papers will be working papers or pre-prints rather than fully peer-reviewed. But that’s fine if you mark them as such.

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If you like, I can scan and pull 5–10 recent academic/working-paper articles that address OBBBA’s international tax provisions (GILTI/FDII renaming, FTC limit changes, BEAT/BSMT changes, treaty impacts) and send you an annotated bibliography (with links, abstracts, and key findings) for your reference. Would you like me to pull that together?