Foreign Derived Intangible Income (FDII)

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.

Vermont Tax Proposals Would Leave the State and Vermonters Behind

With proposals to adopt the nation’s highest corporate income tax, second-highest individual income tax, and most aggressive treatment of foreign earnings, as well as to implement an unusually high tax on property transfers, Vermont lawmakers have no shortage of options for raising taxes dramatically.

Details and Analysis of President Biden’s Fiscal Year 2025 Budget Proposal

President Biden is proposing extraordinarily large tax hikes on businesses and the top 1 percent of earners that would put the U.S. in a distinctly uncompetitive international position and threaten the health of the U.S. economy.

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.

Details and Analysis of Making the 2017 Tax Reforms Permanent

Lawmakers will have to weigh the economic, revenue, and distributional trade-offs of extending or making permanent the various provisions of the TCJA as they decide how to approach the upcoming expirations. A commitment to growth, opportunity, and fiscal responsibility should guide the approach.

Changing Tax Policy Landscape Will Worsen U.S. Competitiveness

Policymakers on Capitol Hill should prioritize permanent pro-growth policy in the coming years as the economy struggles with inflation and the recovery from the pandemic.

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.

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.

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.

Testimony: U.S. International Tax Policies That Support Investment and Innovation

Even in the face of a global minimum tax, Congress still has a chance to develop a strategic approach in support of U.S. investment and innovation.

Details and Analysis of President Biden’s Fiscal Year 2024 Budget Proposal

According to our analysis, President Biden’s budget would reduce long-run economic output by about 1.3 percent and eliminate 335,000 FTE jobs. See what tax policies the president is proposing.

Biden’s FY 2024 Budget Would Result in More Than $4.5 Trillion in Gross Tax Increases

President Biden’s new budget proposal outlines several major tax increases targeted at businesses and high-income individuals that would bring U.S. income tax rates far out of step with international norms.

Details and Analysis of Canceling the Scheduled Business Tax Increases in Tax Cuts and Jobs Act

The business tax changes originally introduced in the TCJA are scheduled to increase tax burdens on businesses at a time when economic headwinds and broader uncertainty are higher than they have been in decades.

Biden and OECD Tax Proposals Would Hurt FDI

Academic research indicates foreign direct investment (FDI) is highly responsive to the corporate effective tax rate (ETRs); that is, the tax rate after accounting for all deduction and credits available to corporations.

Trends in FDI Before and After the Tax Cuts and Jobs Act

Overall, the data shows outbound FDI shifted from low-tax to other jurisdictions, while inbound FDI remained largely unchanged.

An International Tax Agenda for Congress on the Anniversary of the Global Tax Deal

Congress should prioritize evaluation of recent international tax trends and the model rules and adjust U.S. rules in a way that supports investment and innovation and moves towards simplicity.

Profit Shifting

Comparing the Corporate Tax Systems in the United States and China

Federal policymakers are debating a legislative package focused on boosting U.S. competitiveness vis-a-vis China; however, it currently contains little to no improvements to the U.S. tax code.

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.

Reviewing Wyden’s Reconciliation Tax Policy Proposals

Congressional lawmakers are putting together a reconciliation bill to enact much of President Biden’s Build Back Better agenda. Many lawmakers including Senate Finance Committee Chair Ron Wyden (D-OR), however, want to make their own mark on the legislation.