Global Intangible Low Tax Income (GILTI)

Territorial Tax System

Iowa Decouples from 163(j) and GILTI, Clarifies Non-Taxation of PPP Loans

Iowa’s HF 2614, which passed both chambers of the legislature and now waits for the governor’s signature, makes several changes to the state’s tax code, which, although they will affect revenue, will encourage economic growth and make the state’s tax code more competitive.

Tax Policy After Coronavirus: Clearing a Path to Economic Recovery

Governments at all levels must work to remove the tax policy barriers that stand in the way of economic recovery and long-term prosperity following the COVID-19 crisis. Our new guide outlines several comprehensive options that policymakers can take at the federal and state levels.

Kansas, Nebraska, and Utah Lawmakers Pursue “Not GILTI” Verdicts

Taxing GILTI puts states at a competitive disadvantage compared to their peers—all for a tax that makes very little sense at the state level, and which legislators never sought in the first place.

Tax Trends at the Dawn of 2020

From remote sales tax collection to taxes on marijuana and vaping products, we recap the top state tax trends from 2019 and break down which ones you should watch for in 2020.

GILTI and Other Conformity Issues Still Loom for States in 2020

Even two years after enactment of the federal Tax Cuts and Jobs Act (TCJA), many states have yet to issue guidance explaining how they conform to key provisions of the law, particularly those pertaining to international income.

Blending Considerations for Minimum Taxes on Foreign Income

Tax Foundation Response to OECD Public Consultation Document: Global Anti-Base Erosion Proposal (“GloBE”) (Pillar Two)

The tax base for the income-inclusion rule will be just as important as determining the rate, and both the base and the rate will likely impact business decisions. Additionally, policymakers need to determine how the choice for blending fits with the overarching goal of the policy. And as the example of GILTI shows, it is essential to assess how current international tax regulations would interact with a global minimum tax.

Senator Van Hollen Introduces Proposal to Raise Taxes on High-Income Households

Van Hollen’s proposals add to the long list of Democratic Party tax proposals that attempt to both raise additional revenue from corporations and high-income households and make the tax code more progressive and “equitable.”

CFC Rules Around the World

Our paper undertakes a review of controlled foreign corporation (CFC) rules around the world as a contribution to the global discussion over the possible expansion of existing anti-base erosion CFC regimes or the potential adoption of a minimum tax.

Minnesota Policymakers Strike Tax Conformity Deal

Arizona Delivers Rate Cuts and Tax Conformity

Business in America

Who are the workers, consumers, and shareholders who interact with businesses in the U.S.? What forms do these businesses take? How do business taxes impact people’s lives? It is essential we answer these questions in order to design a business tax system that is simple, efficient, and enables economic progress.

Not All Tax Expenditures Are Equal

The debate in Washington, D.C. often centers around tax expenditures, so-called corporate loopholes, in the tax code. But not all tax expenditures are created equal. Some represent neutral tax treatment and should be left alone, while others are distortionary and should be repealed. Understanding what a tax expenditure represents is essential for understanding how our tax code works for both businesses and individuals.

Anti-Base Erosion Provisions and Territorial Tax Systems in OECD Countries

The U.S. decision to adopt a territorial tax system is certainly an improvement over having a worldwide system. However, in moving to a territorial system some of the new features created with the TCJA increased the complexity of the system.

Tax Competition of a Different Flavor at the OECD

What’s up with Being GILTI?

The Tax Cuts and Jobs Act made significant changes to the way U.S. multinationals’ foreign profits are taxed. GILTI, or “Global Intangible Low Tax Income,” was introduced as an outbound anti-base erosion provision.

What Happens When Everyone is GILTI?

Secretary Mnuchin, Finance Minister Le Maire, and other tax policy leaders should encourage the OECD and their own research staff to perform serious economic analysis on the alternatives for changing international tax rules before moving forward. It would be quite unfortunate for the world to learn the wrong lessons from U.S. tax reform.

GILTI Minds: Why Some States Want to Tax International Income—And Why They Shouldn’t

The new federal tax on Global Intangible Low-Taxed Income (GILTI) is something of a misnomer: it’s certainly global and it’s definitely income, but the rest of it is, at best, an approximation. It’s not exclusively levied on low-taxed income, nor just on the economic returns from intangible property. So what is GILTI, why might states tax it, and what’s the problem with that?

Toward a State of Conformity: State Tax Codes a Year After Federal Tax Reform

States incorporate provisions of the federal tax code into their own codes in varying degrees, meaning that federal tax reform has implications for state revenue beyond any broader economic effects of tax reform.