Skip to content
Alan Cole Tax Foundation
Expert

Alan Cole

Senior Economist

Alan Cole is a Senior Economist with Tax Foundation’s Center for Federal Tax Policy. His areas of focus include business taxes, cross-border taxes, and macroeconomics.

In addition to work at Tax Foundation, Alan Cole has served on the Joint Economic Committee and with The Conference Board, and published on a variety of economic topics. Alan has a bachelor’s degree in economics from Yale University and an MBA majoring in finance and public policy from the Wharton School. Alan lives in Washington, D.C., with his wife and daughter.

Written Works

Fatal flaws of OECD Pillar Two Global Minimum Tax Foundation

The Fatal Flaw of Pillar Two

Pillar Two, the international global minimum tax agreement, has a considerable chance of failing and may ultimately allow the same problems it was designed to address.

6 min read
2017 tax reform including the Tax Cuts and Jobs Act TCJA impact of GILTI FDII and BEAT

The Impact of GILTI, FDII, and BEAT

The Tax Cuts and Jobs Act of 2017 (TCJA) reformed the U.S. system for taxing international corporate income. Understanding the impact of TCJA’s international provisions thus far can help lawmakers consider how to approach international tax policy in the coming years.

30 min read
Moore tax case of Moore vs United States consumption tax base

Why Moore v. U.S. Won’t Get Us a Consumption Tax Base

At first glance, a ruling for the plaintiffs in Moore might seem to solve some of the timing problems with the U.S. tax system. Unfortunately, upon greater inspection, such a ruling might create new timing problems. And the more rigid the ruling, the harder it would be to fix the timing problems it would create.

5 min read
Anti-Avoidance Policies in a Pillar Two World including CFC rules and Base erosion and Profit Shifting Pillar Two policies

Anti-Avoidance Policies in a Pillar Two World

The global minimum tax agreement known as Pillar Two is intended to curb profit shifting. However, OECD countries already have a variety of mechanisms in place that seek to prevent base erosion and profit shifting by multinational corporations.

40 min read
US Pillar Two responses should include a policy response from Congress on the OECD global tax deal's global minimum tax

How the U.S. Can Piece Together a Solution for Pillar Two

Congress should recognize that Pillar Two has significant U.S.-specific downsides, but also that it cannot unilaterally stop Pillar Two from taking effect. Instead, it should carefully consider a policy response for the next Congress, when a variety of forces are likely to compel it to act.

7 min read
Risks to the U.S. Tax Base from Pillar Two

Risks to the U.S. Tax Base from Pillar Two

A growing international tax agreement known as Pillar Two presents two new threats to the U.S. tax base: potential lost revenue and limitations on Congress’s ability to set its own tax policy.

39 min read
Carbon Border Adjustment Mechanism EU CBAM carbon price carbon tariffs US global minimum tax US tax incentives Build Back Better tax rate on gilti Global Intangible Low Tax Income (GILTI) Global intangible low-taxed income US cross-border tax reform and GILTI Global Intangible Low Tax Income. Foreign tax credits

JCT Analyzes Federal Revenue Effects of Pillar Two

The JCT analysis raises some useful questions for the U.S. domestic debate over Pillar Two. The Treasury Department should examine its support for an agreement that will reduce its own revenue intake. But it is also worth noting that the principal mechanism for the revenue reduction—the foreign tax credit—is a policy already baked into U.S. law, including the Republican-enacted global minimum tax from 2017. The OECD deal merely takes advantage of this longstanding feature.

6 min read
utpr pillar two us tax base oecd global minimum tax ways and means jason smith

Why Does the UTPR Matter?

As the UTPR is a new concept, it is worth explaining what it is and why Rep. Smith cares about it. In a sentence, the Undertaxed Profits Rule (UTPR) is a looming extraterritorial enforcement mechanism for a tax base the U.S. has not adopted.

6 min read
Tax Expenditures interest deductions, sources of personal income, Gross Receipts Taxes

Interest Deductibility – Issues and Reforms

Interest deductibility creates holes in the tax base, distorts corporate investment strategies, and contributes to a potentially dangerous macroeconomic environment of overleveraging.

20 min read