Blog Articles
6147 Results
Testimony before the House Ways and Means Select Revenue Measures Subcommittee
Watch Nicole Kaeding, Vice President of Federal and Special Projects at the Tax Foundation, testify before the House Ways and Means Select Revenue Measures Subcomittee on the impact of limiting the SALT deduction.
23 min read
How Controlled Foreign Corporation Rules Look Around the World: United States of America
The United States was the first country to enact CFC rules, and it is probably the country with the most complex set of rules that will be presented in this blog series. The rules determine control using a combined ownership test: one for the corporation and the other at the shareholder level. The assessable income under the rules is generally passive income but the amount of foreign income subject to U.S. tax has expanded with the adoption of GILTI.
10 min read
How Patent Boxes Impact Business Decisions
As with every change in tax policy, there are trade-offs. The Modified Nexus Approach adds an additional layer of complexity to the already complex issue of taxing IP income. Linking tax breaks for IP income to its associated R&D activity has changed the game and will likely result in some businesses restructuring and relocating their IP assets and R&D activity. Effective tax rates on IP income will likely play an important role in determining optimal locations, giving measures such as R&D credits more importance. Whether this new approach to IP taxation will impact profit shifting and which countries will be the winners and losers is yet to be seen.
6 min read
CFC Rules Around the World
Our paper undertakes a review of controlled foreign corporation (CFC) rules around the world as a contribution to the global discussion over the possible expansion of existing anti-base erosion CFC regimes or the potential adoption of a minimum tax.
3 min read
In Defense of the “Church Parking Tax”
2 min read
Ripple Effects from Controlled Foreign Corporation Rules
Governments should recognize these trade-offs as they implement controlled foreign corporation (CFC) rules or change their tax policies in ways that increase taxes on foreign subsidiaries.
7 min read
Remembering Martin Feldstein
1 min read
Italy Can Pay for a Flat Tax
4 min read
Putting the Pieces Together on BEPS
Taxes matter for decisions to be made by businesses, individuals, and families, and it is important for policymakers to understand that rules can be designed to be neutral rather than distortionary.
6 min read
