Tax Policy Blog

Millionaire’s Tax Gets Axed from New Jersey Budget

How Controlled Foreign Corporation Rules Look Around the World: Netherlands

The Dutch tax system is characterized by its simplicity and the attractiveness to investors. With the incorporation of CFC rules, the Dutch government protected its tax base from erosion and profit shifting. The Netherlands is facing a whole series of adjustments that would create a more complex system adapted to the international standards recommended by the OECD and adopted by the European Union Council. When revising the rules authorities must be mindful about not making the system more complex and to avoid increasing the compliance burden in the country.

An Overview of the New Markets Tax Credit

How Controlled Foreign Corporation Rules Look Around the World: Japan

Japan is a country with a complex multilayer system to calculate the corporate income tax. As a consequence, the CFC income determination has evolved as a complex set of rules to complement the corporate income tax. It would be a great idea for the Japanese authorities to address a simplification of the rules to facilitate the entry of new capital investments into their economy.

Arguments for Wyoming’s National Retail Fairness Act Partly Based on a Misunderstanding

Beto O’Rourke’s War Tax Is a New Approach

Senator Van Hollen Introduces Proposal to Raise Taxes on High-Income Households

Van Hollen’s proposals add to the long list of Democratic Party tax proposals that attempt to both raise additional revenue from corporations and high-income households and make the tax code more progressive and “equitable.”

Texas Tackles Property Tax Concerns, Can Square Up to Margin Tax

Wisconsin Legislature Sends Budget, Marketplace Provider Bill to Governor

The Regressivity of Deductions

The Economics Behind Thin-Cap Rules

Are Opportunity Zones Working as Intended?

New Research Shows Small Firms Value Simplicity More Than Tax Relief

The Challenges of Consensus in the Digital Economy on the International Tax Treaty System

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.

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.

Millionaires’ Tax Take Two: Massachusetts legislature moves forward Millionaires’ Tax

Maine Hotels and Campgrounds Would Have Felt LOST If Bill Became Law

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.

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.