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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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Time for an Updated Impact Assessment of the Global Tax Deal

This week it was reported that during her recent trip Poland, Treasury Secretary Janet Yellen offered estimates from the EU Tax Observatory as evidence that the Polish government would benefit from supporting the global tax deal. Poland has been cautious to lend its support to the EU legislation to implement the minimum tax rules, and […]

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Rushing Headlong into Formulary Apportionment

One of the greatest challenges of lawmaking is recognizing when a beautiful theory must succumb to an ugly fact. The purity of conceptual policymaking must take the real world into account and acknowledge that things that work well “in theory” sometimes fail spectacularly to meet expectations “in practice.” It would be wonderful if a policy […]

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U.S. Tax Incentives Could be Caught in the Global Minimum Tax Crossfire

The Build Back Better legislative package includes both tax hikes and tax cuts, which contain two contrasting tax policy narratives. Tax hikes include corporate tax increases on foreign income and a new 15 percent domestic minimum tax, and green energy tax incentives provide a tax cut. Policymakers also sought to protect some pre-existing tax incentives from […]

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What the U.S. Can Learn from the Adoption (and Repeal) of Wealth Taxes in the OECD

Recent discussions of a proposed wealth tax for the United States have included little information about trends in wealth taxation among other developed nations. However, those trends and the current state of wealth taxes in OECD countries can provide context for U.S. proposals. The OECD maintains detailed tax revenue statistics for its 38 member countries. […]

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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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What Do Global Minimum Tax Rules Mean for Corporate Tax Policies?

Today, the Organisation for Economic Co-operation and Development (OECD) released model rules for the global minimum tax (also known as Pillar 2). These rules are designed to apply to multinational companies with more than €750 million in total global revenues and place a minimum effective tax rate of 15 percent on those company’s profits. In […]

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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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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) […]