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Global Intangible Low Tax Income (GILTI)

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Tax Foundation Discussion on the Harms of Retaliatory Tax and Trade Policies with Senator Blackburn

Tax Foundation Discussion on the Harms of Retaliatory Tax and Trade Policies

Historical evidence and recent studies have shown that retaliatory tax and trade proposals raise prices and reduce the quantity of goods and services available to U.S. businesses and consumers, resulting in lower incomes, reduced employment, and lower economic output.

5 min read
2017 tax reform including the Tax Cuts and Jobs Act TCJA impact of GILTI FDII and BEAT

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
global tax agreement global tax deal OECD global minimum tax rules corporate minimum tax rules Secretariat Proposal, OECD Public Consultation Document, Unified Approach under pillar one profit shifting definition tax planning and avoidance foreign direct investment FDI global tax deal impact of global tax agreement OECD international tax proposal

The Latest on the Global Tax Agreement

The agreement represents a major change for tax competition, and many countries will be rethinking their tax policies for multinationals.

7 min read
Details and Analysis of Making 2017 Tax Reform Permanent

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.

18 min read
Tax Cuts and Jobs Act or TCJA corporate tax was boosted as part of broader economic effects of the 2017 tax law

New Study Finds TCJA Strongly Boosted Corporate Investment

The 2017 Tax Cuts and Jobs Act (TCJA) was the largest corporate tax reform in a generation, lowering the corporate tax rate from 35 percent to 21 percent, temporarily allowing full expensing for short-lived assets (referred to as bonus depreciation), and overhauling the international tax code.

6 min read
Anti-Avoidance Policies in a Pillar Two World including CFC rules and Base erosion and Profit Shifting Pillar Two policies

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
It Pays to Keep It Simple including for Tax Compliance and Tax Revenue in the form of Tax Simplicity

It Pays to Keep It Simple

Simplicity in the tax code means taxes should be easy for taxpayers to pay and easy for governments to administer and collect.

US Pillar Two responses should include a policy response from Congress on the OECD global tax deal's global minimum tax

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
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
Carbon Border Adjustment Mechanism EU CBAM carbon price carbon tariffs US global minimum tax US tax incentives Build Back Better tax rate on gilti Global Intangible Low Tax Income (GILTI) Global intangible low-taxed income US cross-border tax reform and GILTI Global Intangible Low Tax Income. Foreign tax credits

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
utpr pillar two us tax base oecd global minimum tax ways and means jason smith

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
Minnesota income tax reform bill

Minnesota’s Omnibus Tax Bill Would Undermine the State Economy

As policymakers in St. Paul finalize this year’s tax bill, they should avoid policies that incentivize the diversion or relocation of capital. Importantly, states do not institute tax policy in a vacuum. The evidence from states’ experiences and the academic literature supports the conclusion that tax competitiveness matters not just to businesses but to human flourishing.

15 min read