Skip to content

Global Tax Deal

All Related Articles

GILTI by country not as simple

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.

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.

OECD BEPS Higher Corporate Tax Revenues Globally Despite Lower Tax Rates

Pillars, Blueprints, an Impact Assessment, and Construction Delays

The OECD released blueprints for proposals on changing international tax rules alongside an impact assessment based on the overall design of the proposals. While the blueprints cover proposals both for changing where large multinationals owe corporate tax and designing a global minimum tax, there are still many unanswered questions. In the meantime, other digital tax proposals are moving forward and have the potential to result in a harmful tax and trade war.

Designing a Global Minimum Tax with Full Expensing

The design and implementation of a global minimum tax is not simple and straightforward. There are dozens of challenging issues that policymakers will need to consider. So, when it comes to the way the minimum tax treats new investment, it seems clear that incorporating full expensing into the design would have significant benefits.

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

Decades in Corporate Taxation

Corporate taxation has evolved significantly, with rates coming down significantly over the last several decades. Countries have redesigned their tax bases by changing the treatment of losses, interest, and capital costs. A recent OECD report highlights the general stabilization of corporate tax revenues and statutory rates alongside major changes to address profit-shifting opportunities.

Germany tax, German EU presidency Germany EU presidency

Tax Policy Proposals for the German EU Presidency

While much of Germany’s EU presidency agenda is focused on policies to ensure economic stability and recovery from the COVID-19 pandemic, there’s a pair of tax proposals that the country is planning to develop and move forward at the EU level: a financial transaction tax and a minimum effective tax.

A Blow to Pillar 1

The U.S. has called for a pause in global digital tax negotiations, dealing a blow to Pillar 1 of the OECD’s international tax project. What happens next could be very harmful for the global economy.