Global Intangible Low Tax Income (GILTI)

Details and Analysis of President Biden’s American Jobs Plan

Details and analysis of the American Jobs Plan tax proposals. Learn more about the major tax changes in the proposed Biden infrastructure plan.

Two Important Issues that Must Be Resolved in “Global Tax Reform”

If the U.S. is suggesting a 15 percent effective rate as the minimum acceptable rate for a global agreement, then the tax bases of the various minimum taxes adopted as part of the agreement should be aligned to minimize complexities and unintended consequences.

Biden Administration Changes to GILTI and FDII Will Yield Automatic State Tax Increases

State taxation of GILTI is unconventional and economically uncompetitive and will become even more so if the federal government adopts a more aggressive approach to taxing GILTI, as outlined in the American Jobs Plan Act.

Pleading GILTI: A Guide to the Complicated World of Global Intangible Low Tax Income

On this episode of The Deduction, we speak with Pam Olson, Tax Foundation Board Member and Consultant on Tax Policy Services at PwC, about the tax on Global Intangible Low Tax Income, or “GILTI.” In 2017, GILTI was implemented as a minimum tax designed to disincentivize U.S. companies from shifting profits overseas, but it doesn’t work how drafters intended, and now President Biden has proposed doubling it.

GILTI by Country Is Not as Simple as it Seems

If policymakers want a recipe to dramatically expand the complexity of U.S. international tax rules and the burden on U.S. multinational businesses, then a tax on foreign earnings calculated at the country level would be the way to do it. Alternatively, policymakers could focus on mitigating the unintended consequences of GILTI and other recent international tax rules.

Outlier No More: Kansas Adopts Tax Reform with Wayfair Safe Harbor, GILTI Exclusion

After three years of deliberations, more than two-thirds of members in both the Senate and the House enacted tax reform and relief legislation Monday over the veto of Gov. Laura Kelly (D).

Tax Policy in the First 100 Days of the Biden Administration

In his first 100 days as president, Joe Biden has proposed more than a dozen significant changes to the U.S. tax code that would raise upwards of $3 trillion in revenue and reduce incentives to invest, save, and work in the United States.

Kansas Lawmakers to Consider Veto Override on Tax Reform Bill

Kansas has the revenue cushion it needs to provide tax relief to individuals and businesses and improve the structure of its tax code in the process. These pro-growth reforms would not only help taxpayers amid the pandemic but would also promote economic recovery and growth in a state that is lagging behind its competitors.

Effects of Proposed International Tax Changes on U.S. Multinationals

The international corporate tax changes in President Biden’s tax plan would increase tax rates on domestic income more than on foreign income, resulting in a net increase in profit shifting out of the US, according to our Multinational Tax Model.

Excluding GILTI and Reducing the Corporate Tax Rate Would Improve Nebraska’s Economic Competitiveness

Excluding Global Intangible Low-Taxed Income (GILTI) from taxation and reducing the state’s top marginal corporate rate would improve the state’s economic competitiveness and are among the top income tax modernization priorities Nebraska policymakers ought to consider.

Biden’s Tax Plan Would Restore U.S. Exceptionalism—But Not in a Good Way

No other country has tried to enforce some of the policies that the Biden administration is proposing. Embarking on such uncharted course would set the U.S. apart from global tax policy norms and best practices and could harm American competitiveness.

The Balancing Act of GILTI and FDII

The tax treatment of intangible assets has come into the spotlight recently with the Biden administration proposing to undo a policy adopted in 2017 to encourage intellectual property (IP) to be located in the U.S.

President Biden’s Infrastructure Plan Raises Taxes on U.S. Production

An increase in the federal corporate tax rate to 28 percent would raise the U.S. federal-state combined tax rate to 32.34 percent, higher than every country in the OECD, the G7, and all our major trade partners and competitors including China.

TCJA Is Not GILTI of Offshoring

Many members of Congress have taken issue with the 2017 tax reform. However, the reasoning that has led some to believe that GILTI provides a path to offshoring investment and jobs is flawed.

How GILTI Are U.S. Industries?

Both the Biden campaign and some Democratic members of Congress have recommended changes to GILTI, but before doing that, policymakers should consider how GILTI’s design can have ramifications for many U.S. companies and their tax burdens.

Foreign-Derived Intangible Income (FDII)

Global Intangible Low-Taxed Income (GILTI)

International Tax Rule

Testimony: Prioritizing Comprehensive Tax Modernization in Nebraska

The Nebraska legislature has an excellent opportunity to make progress toward a simpler, stabler, less burdensome, and more competitive tax code.

Can GILTI and the GloBE be Harmonized in a Biden Administration?

While there are several parts of the policy that are subject to further discussion and agreement, GloBE is expected to be different from GILTI in several ways.