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Trends in FDI Before and After the Tax Cuts and Jobs Act

The Tax Cuts and Jobs Act (TCJA) of 2017 made several changes to the U.S. tax system to enhance competitiveness and discourage profit shifting to low-tax jurisdictions by U.S. multinationals. Among them were a new 10 percent minimum tax on companies with significant cross-border transactions (BEAT) and new tax rates on deemed intangible income (GILTI […]

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An International Tax Agenda for Congress on the Anniversary of the Global Tax Deal

Key Findings A year since the global tax deal was agreed to by more than 130 countries, progress on implementing legislation has hit a lull. Implementation of the minimum tax rules is not expected until the end of 2023 or in 2024. Since the 2017 U.S. tax reforms and other recent international rules changes, onshoring […]

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4 Things to Know About the Global Tax Debate

The taxation of large companies has been in the spotlight recently as governments around the world have sought to make significant changes to how corporate profits are taxed in a global economy. Last year more than 130 jurisdictions agreed to an outline of policies that would change where companies pay taxes and institute a global […]

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Comparing the Corporate Tax Systems in the United States and China

Key Findings Federal policymakers are debating a legislative package focused on boosting U.S. competitiveness vis-a-vis China; however, it currently contains little to no improvements to the U.S. tax code. The existing U.S. tax code is biased against capital investment and it is scheduled to worsen over the next decade. The tax bias against domestic investment […]

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The Global Minimum Tax Changes the Game for Build Back Better Revenue

The global minimum tax has upended many conversations about international tax policy, including in the United States. The goal of the policy is to set a worldwide 15 percent minimum effective tax rate on corporate profits and enforce it through a set of interconnected rules. If enough countries adopt those rules, then even those that […]

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Gift or Lump of Coal: U.S. Cross-border Tax Changes Won’t Be Home for Christmas

As 2021 comes to a close, countries are moving toward harmonizing tax rules for multinationals, but stalled talks on the Build Back Better Act (BBBA) in the United States means new uncertainties for a global agreement and for taxpayers. Despite the 2017 U.S. tax reform serving as inspiration for current discussions of a global minimum […]

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The Interest Limitation Pile-On

How should tax policy treat interest expenses? Historically, corporate income tax systems in the U.S. and around the world have allowed businesses to deduct their interest paid. As Congress contemplates adding a new worldwide interest limitation rule as part of the Build Back Better Act (BBBA), it is useful to consider the potential effects of […]

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Which Industries Would the Tax Hikes Target?

A recent Tax Foundation analysis considered how various proposals from the Biden administration, from Congress, and from the Organisation for Economic Co-operation and Development would affect the effective tax rates (ETRs) on the foreign profits of U.S. multinationals. That analysis focused on how each policy and proposal would affect the overall ETRs. But which industries […]

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How Heavily Taxed Are U.S. Multinationals?

Recent proposals from the Biden administration and congressional Democrats aim to hike taxes on the foreign profits of U.S. multinationals, resting on the claim that U.S. multinationals pay very low tax rates on these foreign profits. But how heavily taxed are they, and how would various proposals affect these tax rates? U.S. multinational enterprises (MNEs) […]

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Treasury Minimum Tax Argument Relies on Narrow Interpretation of Current/Proposed Rules

Tuesday, the U.S. Treasury Department released a blog authored by Treasury officials Itai Grinberg and Rebecca Kysar. Though the blog purports to make a case for President Biden’s proposal to increase the current minimum tax on foreign profits of U.S. companies, its arguments rely on a very narrow interpretation of current law and the president’s […]