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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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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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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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What’s in the New Global Tax Agreement?

In recent years, countries have been debating significant changes to international tax rules that apply to multinational companies. This week there was a breakthrough in discussions, and an outline for the new rules was released by the Organisation for Economic Co-operation and Development (OECD). If today’s global tax agreement is fully implemented, large U.S. companies […]

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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 […]

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OECD Report: Tax Revenue as a Percent of GDP in Latin American and Caribbean Countries Is below the OECD Average

The Organisation for Co-operation and Economic Development (OECD) has compiled tax revenue data for countries around the world—including 27 Latin American and Caribbean (LAC) countries, where tax revenue as a percent of GDP is on average 11 percentage points lower than in other regions. On average, the tax-to-GDP ratio for 26 countries (excluding Venezuela due […]