Global Intangible Low Tax Income (GILTI)

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.

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.

How the Moore Supreme Court Case Could Reshape Taxation of Unrealized Income

A major case pending before the U.S. Supreme Court (Moore v. United States) is calling into question provisions on large portions of the U.S. tax base which could quickly become legally uncertain, putting significant revenue at stake.

Risks to the US Tax Base from Pillar Two

A growing international tax agreement known as Pillar Two presents two new threats to the US tax base: potential lost revenue and limitations on Congress’s ability to set its own tax policy.

Testimony: Reviewing Recent Federal Tax Policies and Considering Pro-Growth Reforms

Lawmakers should focus on simplifying the federal tax code, creating stability, and broadly improving economic incentives. There are incremental steps that can be made on the path to fundamental tax reform.

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.

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.

Minnesota Looks to Raise Taxes despite Projected $17.6 Billion Budgetary Surplus

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.

New Jersey Should Take Opportunity to Make Corporate Taxes More Competitive

By letting the corporate surtax expire, eliminating taxes on GILTI, and embracing full expensing, New Jersey would take important steps toward creating a more welcoming and competitive tax environment.

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.

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 New Tax Proposals Are Complicated and Rife with Double Taxation

Tax reform should be about increasing fairness. And the way to get there is by reducing complexity and double taxation, not by doubling down on them.

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.

EU Taxation: Prioritizing Geopolitics over Revenue

If the EU wants to strategically compete with economic powers like the United States or China, it needs principled, pro-growth tax policy that prioritizes efficient ways to raise revenue over geopolitical ambitions.

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.

Undertaxed Profits Rule (UTPR)

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.