Global Tax Deal

How Heavily Taxed Are U.S. Multinationals?

In general, the effective tax rates on the foreign profits of U.S. multinationals are not that low relative to the U.S. tax rate, contrary to popular rhetoric.

Choose Your Own Adventure: Global Minimum Tax Edition

Over the course of the last year, it has become clear that Democratic lawmakers want to change U.S. international tax rules. However, as proposals have surfaced in recent weeks, there are clear divides among various proposals.

Treasury Minimum Tax Argument Relies on Narrow Interpretation of Current/Proposed Rules

As Congress prepares to rewrite some portion of the current international tax rules, it’s hoped that they are able to achieve a more principled approach and one that is not so subject to obfuscation and misinterpretation.

Tax Foundation Response to Ireland Department of Finance Consultation Document: Consultation on OECD International Tax Proposals

The recent effort to change international tax rules has been one of significant contradictions. The proposals have been driven by arguments about the need to raise additional revenues, to stabilize corporate tax rates, or to prevent offshoring. However, upon closer examination, these three arguments fail to capture what is occurring.

Case Study: Global Tax Deal

What is the OECD Global Tax Deal and what impact will it have on U.S. and foreign multinationals? Learn about the OECD’s efforts to prevent companies from shifting profits—including Pillar 1, which is focused on changing where companies pay taxes, and Pillar 2, which would establish a global minimum tax.

Expense Allocation: A Hidden Tax on Domestic Activities and Foreign Profits

While arcane, expense allocation rules are relevant to current debates because they result in a heavier tax burden for U.S. companies under current law than the recently negotiated global minimum tax proposal.

Adoption of Global Minimum Tax Could Raise U.S. Revenue…or Not

This interaction between the U.S. proposals and those that may be put into law in foreign jurisdictions should give lawmakers caution when evaluating the revenue potential of changes to GILTI.

Insights from the UN World Investment Report for Global Tax Reform

The United Nations (UN) recently released its annual “World Investment Report,” which shows the dramatic fall in global foreign direct investment (FDI) caused by the COVID-19 crisis.

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

From a policy perspective it is appropriate to combat base erosion and profit shifting, but policymakers need to keep in mind the need for simplicity to avoid increasing the compliance burden on taxpayers and administrative burdens on tax authorities.

A Global Minimum Tax and Cross-Border Investment: Risks & Solutions

Leaders around the world are quickly moving to finalize an agreement on a global minimum tax in 2021, based on the so-called “Pillar Two” proposal from the OECD.

Details and Analysis of President Biden’s FY 2022 Budget Proposals

Explore President Biden budget proposals, including tax and spending in American Jobs Plan and American Families Plan. See Biden tax and spending proposals.

G7 Agrees to Global Minimum Tax

One of the hottest topics in the tax world today is the recent announcement by G7 finance ministers that they would support enacting a new, 15-percent global minimum tax. We dive into the economic and political implications and how such a tax would impact global economies, revenues, and real people.

Carve-ins and Carve-outs: Open Questions for Global Tax Reform

There has been some confusion about how some parts of the recent G7 agreement on new tax rules for multinational companies might work. The new policies would target the largest and most profitable multinationals and bring in a global minimum tax.

Two Important Issues that Must Be Resolved in “Global Tax Reform”

If the U.S. is suggesting a 15 percent effective rate as the minimum acceptable rate for a global agreement, then the tax bases of the various minimum taxes adopted as part of the agreement should be aligned to minimize complexities and unintended consequences.

GILTI by Country Is Not as Simple as it Seems

If policymakers want a recipe to dramatically expand the complexity of U.S. international tax rules and the burden on U.S. multinational businesses, then a tax on foreign earnings calculated at the country level would be the way to do it. Alternatively, policymakers could focus on mitigating the unintended consequences of GILTI and other recent international tax rules.

Biden’s Tax Plan Would Restore U.S. Exceptionalism—But Not in a Good Way

No other country has tried to enforce some of the policies that the Biden administration is proposing. Embarking on such uncharted course would set the U.S. apart from global tax policy norms and best practices and could harm American competitiveness.

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.

Base Erosion and Anti-Abuse Tax (BEAT)

Foreign-Derived Intangible Income (FDII)

Global Intangible Low-Taxed Income (GILTI)