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Global Intangible Low Tax Income (GILTI)

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Tax Cuts and Jobs Act offshoring Controlled Foreign Corporation rules around the world CFC rules US CFC rules passive foreign investment companies, PFICs GILTI, global minimum tax

TCJA Is Not GILTI of Offshoring

Many members of Congress have taken issue with the 2017 tax reform. However, the reasoning that has led some to believe that GILTI provides a path to offshoring investment and jobs is flawed.

6 min read
International tax rules, International Tax rules House Democrats' covid-19 relief proposal

How GILTI Are U.S. Industries?

Both the Biden campaign and some Democratic members of Congress have recommended changes to GILTI, but before doing that, policymakers should consider how GILTI’s design can have ramifications for many U.S. companies and their tax burdens.

6 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

U.S. Cross-border Tax Reform and the Cautionary Tale of GILTI

The Biden campaign and Senate Democrats identified changes to GILTI that would increase the taxes U.S. companies pay on their foreign earnings. Rather than tacking on changes to a system that is currently neither fully territorial nor worldwide, policymakers should evaluate the structure of the current system with a goal of it becoming more, not less, coherent.

51 min read
American Rescue Plan state tax cuts Treasury clarification Biden international tax team, US treasury biden international tax appointees, Assistant Secretary in the Office of Tax Policy, Tax Policy as Deputy Assistant Secretary for Multilateral Tax, Kimberly Clausing, Rebecca Kysar and Itai Grinberg.

Personnel Is Policy: Biden International Tax Team Edition

This week, the Treasury Department added several new appointees as staffing continues following President Biden’s inauguration. Among them were three scholars of international tax policy: economist Kimberly Clausing and law professors Rebecca Kysar and Itai Grinberg. These three will be influential in developing the administration’s approach to changing U.S. tax rules for multinational corporations and negotiating international tax policy changes at the Organisation for Economic Co-operation and Development (OECD).

4 min read
Nebraska income tax reform and Nebraska tax relief pro-growth tax modernization in nebraska Nebraska Tax Modernization A Key to Economic Recovery and Growth in Nebraska

Thirteen Priorities for Pro-Growth Tax Modernization in Nebraska

We identify 13 of the highest tax reform priorities Nebraska policymakers should consider in their effort to create a more growth-friendly tax code. We also offer a sample comprehensive tax reform plan to show one way policymakers could begin tackling these objectives over the next couple legislative sessions, with further progress to be made in the years ahead.

8 min read
Biden Made in America manufacturing plan to boost R&D

Reviewing Joe Biden’s Tax Vision

Biden’s tax vision is twofold: higher taxes on high-income earners and businesses paired with more generous provisions for specific activities and households.

4 min read

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.

4 min read

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.

26 min read
trends in state tax policy, 2019 state tax trends

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.

38 min read