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Cody Kallen

Cody Kallen was a Resident Fellow at the Tax Foundation, where he worked on federal tax policy and tax model development.

Latest Work

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
Ways & means tax proposal seeks to combat extraterritorial taxes and discriminatory taxes Global minimum tax revenue OECD Pillar Two revenue OECD impact assessment OECD Pillar One tax Pillar one amount a Biden interest limitation Biden interest deduction rule Biden interest expense limitation Business interest expense limitation Democrat Senate international tax overhaul discussion draft legislation (Wyden Brown Warner international tax overhaul) or Sen Wyden international tax plan,

The Interest Limitation Pile-On

As Congress contemplates adding a new worldwide interest limitation rule as part of the House Build Back Better Act, it is useful to consider the potential effects of this proposal as well as whether it is necessary to add this on top of the U.S.’s existing restrictions on the value of interest deductions.

9 min read
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How Do Build Back Better Taxes Affect 5G Competition?

One unintended consequence of the tax proposals in the Build Back Better Act is a higher potential burden on wireless spectrum investments, which could slow the build out of 5G technology as the U.S. races to compete with other countries—moving in the opposite direction of countries like China that are actively subsidizing 5G expansion.

5 min read
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Which Industries Would the Tax Hikes Target?

Using Tax Foundation’s Multinational Tax Model, we estimate the effective tax rates on controlled foreign corporation (CFC) profits under current law and under each of the proposed plans for business tax hikes.

9 min read
Analysis of the Cost-of-Living Refund Act of 2019 Sherrod Brown Ro Khanna, EITC expansion low-income credit

How Heavily Taxed Are U.S. Multinationals?

In general, the effective tax rates on the foreign profits of U.S. multinationals are not that low relative to the U.S. tax rate, contrary to popular rhetoric.

7 min read
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International Tax Proposals and Profit Shifting

There are many ways the U.S.’s international tax rules could be changed, reformed, improved, or worsened. Reflexively jacking up taxes on U.S. multinationals does not necessarily accomplish the goal of reducing or eliminating profit shifting, and it would in fact worsen it.

6 min read