Ideas, Not Mandates: Lessons Learned from a Decade of International Tax Reform
The past decade’s record suggests that countries have reliable legislative methods to improve their tax systems through ordinary tax reforms.
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The past decade’s record suggests that countries have reliable legislative methods to improve their tax systems through ordinary tax reforms.
22 min read
Our analysis of the major tax provisions included in the OBBBA finds it will increase long-run GDP by 0.7 percent. The major tax provisions will reduce federal tax revenue by nearly $5.2 trillion between 2025 and 2034, on a conventional basis.
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The Trump administration has rightly shifted its focus from pursuing legislative changes to implementing new permanent rules. But in this shift, it’s crucial that the White House doesn’t lose focus on the larger task at hand.
The agreement represents a major change for tax competition as well, and many countries will rethink their tax policies for multinationals. However, the US will continue to chart its own course, and other countries may prefer to do the same, depending on the final outcome of the G7 statement.
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The OBBBA moved the US international tax system in the right direction on several fronts. However, some of the changes, while encouraging certain domestic activity and exports, may harm physical activity abroad that supports US competitiveness and domestic activity.
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Even when international relations are frayed, there is value in finding ways to combat corporate profit shifting while also fostering a healthy commercial atmosphere and positive trade relations.
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The One Big Beautiful Bill Act makes many of the individual tax cuts and reforms of the TCJA permanent. It improves upon the TCJA by making expensing for R&D and equipment permanent. However, for the most part, it does not include further structural reforms, and instead introduces many new, narrow tax breaks to the code, adding complexity and raising revenue costs.
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The Senate draft overall makes more changes to international tax policy than the House draft. On net the changes are positive.
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Our preliminary analysis finds the tax provisions increase long-run GDP by 0.8 percent and reduce federal tax revenue by $4.0 trillion from 2025 through 2034 on a conventional basis before added interest costs.
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The US Ways and Means Committee’s “Big Beautiful Bill” includes a retaliatory provision called Section 899, along with an expansion of the base erosion and anti-abuse tax (BEAT).
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Tax legislation in 2025 may have good reason to address international corporate income taxes, because of scheduled changes slated to go into effect or because of international developments like the Pillar Two agreement.
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The Tax Foundation uses and maintains a General Equilibrium Model, known as our Taxes and Growth (TAG) Model to simulate the effects of government tax and spending policies on the economy and on government revenues and budgets.
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On tax policy, Harris carries forward much of President Biden’s FY 2025 budget, including higher taxes aimed at businesses and high earners. She would also further expand the child tax credit (CTC) and various other tax credits and incentives while exempting tips from income tax.
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Lawmakers should consider compliance costs—not just tax liabilities—when evaluating reforms to business income taxation.
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President Biden is proposing extraordinarily large tax hikes on businesses and the top 1 percent of earners that would put the US in a distinctly uncompetitive international position and threaten the health of the US economy.
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BEAT is intended to address a legitimate problem, and there are virtues to BEAT’s overall strategic approach; however, its execution leaves room for improvement.
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Lawmakers should aim for policies that support investment and hiring in the United States and refining anti-avoidance measures to improve administrability and lower compliance costs.
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.
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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.
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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.
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