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How Would House Dems’ Tax Plan Change Competitiveness of U.S. Tax Code?

The International Tax Competitiveness Index has been used to compare the tax systems of OECD countries since 2014. At that time, the United States ranked 28th out of 36 countries in the Index. Following the 2017 tax reform, the rank improved dramatically, to 20th, and the U.S. now ranks 21st. The legislation put forward by […]

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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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Tax Foundation Comments on the Wyden, Warner, Brown Discussion Draft

Introduction Tax Foundation welcomes the opportunity to offer comments on the Wyden, Warner, Brown discussion draft on international taxation. 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, […]

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GILTI of Neglecting Losses

Sometimes the more you learn about a tax policy, the more it confuses you. Many times, the confusion lies between the intent of the policymakers and what really happens. Often, it’s when important issues were overlooked when the policy was being designed. Such is the case for U.S. companies that run losses on their domestic […]

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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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Options for Reforming the Taxation of U.S. Multinationals

Key Findings We analyze four options for changing the taxation of U.S. muiltinationals: the full Biden administration proposal raises the federal corporate income tax liabilities of U.S. multinationals by $1.37 trillion over a decade; a partial version raises $580 billion; making GILTI consistent with Pillar 2 raises $137 billion; and a revenue-neutral option to fix […]

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Will FDII Stay or Will it Go?

Last week the Organisation for Economic Co-operation and Development (OECD) released an updated list of “Harmful Tax Practices” that have been identified as part of a country peer review process. One notable element of the recent list states that the United States has committed to abolish the deduction for Foreign Derived Intangible Income (FDII). However, […]

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Piling on the GILTI Verdicts

The Biden administration has proposed to significantly increase the tax burden on foreign income through a policy known as Global Intangible Low-Tax Income (GILTI). While the administration’s rhetoric focuses on doubling the tax rate on GILTI from 10.5 percent to 21 percent, this is less than half the story. The rate on GILTI is going […]