Graduation Year


Date of Submission


Document Type

Open Access Senior Thesis

Degree Name

Bachelor of Arts



Reader 1

Andrew Finley

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Terms of Use for work posted in Scholarship@Claremont.

Rights Information

2018 Ryan J Motter

OCLC Record Number



In this paper, I talk about Section 965, also known as the transition tax, enacted in the Tax Cuts and Jobs Act (TCJA). First, I examine loopholes under the old tax regime that allowed for the accumulation of offshore earnings and how the TCJA closes those loopholes. After detailing the legislation of the transition tax and a comparison with Section 965 included in the American Jobs Creation Act in 2004, I compare firms’ recorded provisions of the transition tax with an estimation based on the past disclosures of firms’ permanently reinvested earnings and finds that the transition tax will generate an estimated $308 billion in tax revenue. Lastly, I propose three alternate scenarios to the transition tax: taxing all offshore earnings under the GILTI regime, treating offshore cash as eligible for the 21% corporate rate, and a ratable payment plan compared to the current phase-in payment plan.