Fadi Shaheen (Rutgers; Google Scholar), Is the UTPR a 100 Percent Tax on a Deemed Distribution?, 181 Tax Notes Fed. 481 (Oct. 16, 2023):

In this article, Shaheen floats the proposition that from a U.S. tax perspective, the UTPR is the mathematical, conceptual, and legal equivalent of a 100 percent withholding tax on a deemed distribution by the UTPR entity, and he addresses questions that would follow regarding the desirability of such a confiscatory tax and its interaction with tax treaties. …

Conclusion
A lot has been said about the UTPR. This article suggests a different approach for thinking about it, with the hope that this suggestion can add something to the conversation and contribute to our understanding of this unusual tax.m