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Foreign Derived Intangible Income (FDII)

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Kamala Harris Tax Plan 2024 Details Analysis

Kamala Harris Tax Plan Ideas: Details and Analysis

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.  

17 min read

Patent Box Regimes in Europe, 2024

The aim of patent boxes is generally to encourage and attract local research and development (R&D) and to incentivize businesses to locate IP in the country. However, patent boxes can introduce another level of complexity to a tax system, and some recent research questions whether patent boxes are actually effective in driving innovation.

3 min read
Puerto Rico Tax Competitiveness and Pillar Two Global Tax Deal

Puerto Rican Competitiveness and Pillar Two

Puerto Rico, a US territory with a limited ability to set its own tax policies, will be the first part of the US to be substantially affected by Pillar Two, the global tax agreement that seeks to establish a 15 percent minimum tax rate on corporate income.

17 min read
The Impact of BEPS 1.0 base erosion and profit shifting from the OECD and Tax Cuts and Jobs Act corporate international taxation

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.

22 min read
Vermont tax proposals 2024 Montpelier state capitol

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.

7 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
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
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
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
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
Inflation Reduction Act minimum tax or Inflation Reduction Act corporate minimum tax Biden OECD tax proposals hurt FDI Ways and Means proposal profit shifting, federal corporate income tax liabilities under Ways and Means profit shifting proposal

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.

3 min read