Pillar Two: Electric Boogaloo
The global tax deal and Pillar Two are shaking up the tax landscape worldwide, introducing a web of complexity and confusion.
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.
Latest Work
Puerto Rican Competitiveness and Pillar Two
Puerto Rico, a US territory with a limited ability to set its own tax policies, will be the first part of the US to be substantially affected by Pillar Two, the global tax agreement that seeks to establish a 15 percent minimum tax rate on corporate income.
17 min read
Supreme Court Rules against Moores 7-2, Leaves Most Questions Undecided
The government won in Moore. However, given the narrow opinion of the court and the reasoning in the Barrett concurrence and the Thomas dissent, it seems likely that future rulings under other facts and circumstances could favor taxpayers instead.
7 min read
Why We’re Closely Watching Moore v. U.S.
The Moore case could have important impacts on tax policy.
5 min read
How to Improve the Base Erosion and Anti-Abuse Tax
BEAT is intended to address a legitimate problem, and there are virtues to BEAT’s overall strategic approach; however, its execution leaves room for improvement.
7 min read
The Impact of BEPS 1.0
The global landscape of international corporate taxation is undergoing significant transformations as jurisdictions grapple with the difficulty of defining and apportioning corporate income for the purposes of tax.
22 min read
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
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
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
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
The Warning Signs Are Flashing Red on US Debt
Bond markets are screaming for a return to deficit reduction politics. Unfortunately, most policymakers are failing to listen to what the markets are telling them.
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
How the Moore Supreme Court Case Could Reshape Taxation of Unrealized Income
A major case pending before the U.S. Supreme Court (Moore v. United States) is calling into question provisions on large portions of the U.S. tax base which could quickly become legally uncertain, putting significant revenue at stake.
7 min read
Risks to the US Tax Base from Pillar Two
A growing international tax agreement known as Pillar Two presents two new threats to the US tax base: potential lost revenue and limitations on Congress’s ability to set its own tax policy.
39 min read
Interesting Interest Rates
Interest rates and tax policy, two vital components of our economic landscape, often interact in fascinating ways. They influence the behavior of individuals, businesses, and governments. But how exactly?
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
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
Do Consumption Taxes Do a Better Job of Taxing Criminals?
One of the arguments in favor of the FairTax is that it would do a better job of taxing the underground economy than the income tax it is intended to replace.
6 min read
Why Temporary Corporate Income Tax Cuts Won’t Generate Much Growth
Real tax reform should boost incomes for all. A corporate income tax cut could be a means to do that, but not if it’s temporary. A temporary cut is less likely to promote growth and less likely to benefit American workers.
14 min read
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.
17 min read