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What’s Next for Tax Competition?

The recent agreement on a global minimum tax and other changes to tax rules around the world have called into question the future of tax competition. It is difficult to anticipate how tax competition will ultimately be impacted by these changes, although I seriously doubt that the usefulness of Tax Foundation’s International Tax Competitiveness Index […]

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Testimony: EU Parliament Subcommittee on Tax Matters Hearing on the Impact of National Tax Reforms on the EU Economy

Note: The following is the testimony of Daniel Bunn, Tax Foundation Vice President of Global Projects, prepared for a EU Parliament Subcommittee on Tax Matters hearing on October 11, 2021, regarding the impact of national tax reforms on the EU economy. Thank you for the opportunity to testify today. My name is Daniel Bunn, and I am Vice President […]

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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 […]

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Tax Foundation Response to Ireland Department of Finance Consultation Document: Consultation on OECD International Tax Proposals

Introduction Tax Foundation welcomes the opportunity to respond to the public consultation on the OECD International Tax Proposals. Tax Foundation is a nonprofit think tank based in Washington, D.C., and our mission is to improve lives through tax policies that lead to greater economic growth and opportunity. We use the four principles of simplicity, neutrality, […]

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Expense Allocation: A Hidden Tax on Domestic Activities and Foreign Profits

The U.S. corporate tax code is a complicated behemoth, loaded with numerous arcane provisions—some of these providing special tax breaks, others imposing special tax penalties. Among the latter group, indirect expense allocation rules penalize domestic activities and impose a hidden surtax on foreign profits. While arcane, expense allocation rules are relevant to current debates because […]

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Adoption of Global Minimum Tax Could Raise U.S. Revenue…or Not

The Biden administration has proposed significant changes to the tax rules that govern how much U.S. companies owe on their foreign profits while working to negotiate a global minimum tax. However, the global minimum tax and the Biden administration’s proposals are quite different. A recent Tax Foundation report dug into the details on the revenue […]

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Insights from the UN World Investment Report for Global Tax Reform

The United Nations (UN) recently released its annual “World Investment Report,” which shows the dramatic fall in global foreign direct investment (FDI) caused by the COVID-19 crisis. A partial recovery is expected for 2021, with the most optimistic scenario showing a return to 2019 FDI levels by 2022. However, uncertainty remains high, with the ongoing […]

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Eight Ways to Compare the Biden Proposals to the Global Minimum Tax

Recent discussions of a global minimum tax may lead many to believe that there is just one proposal being discussed for the world. That is not the case. While President Biden has led a renewed effort on global negotiations over minimum taxation, his own proposals for U.S. companies differ significantly from proposals that had previously […]

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Carve-ins and Carve-outs: Open Questions for Global Tax Reform

There has been some confusion about how some parts of the recent G7 agreement on new tax rules for multinational companies might work. The new policies would target the largest and most profitable multinationals and bring in a global minimum tax. The G7 agreement is subject to further debate and further agreement at the G20 […]