The Latest on the Global Tax Agreement
The agreement represents a major change for tax competition, and many countries will be rethinking their tax policies for multinationals.
8 min read
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Short FormWhat You Need to Know about the Global Tax Deal
The technical rules that were once solely the province of tax wonks in D.C. and Paris are being brought out into the public sphere.
5 min read
Testimony: The OECD’s Pillar One Project and the Future of Digital Services Taxes
If a multilateral solution to remove digital services taxes (DSTs) is not agreed to, then DSTs will continue to spread and mutate with negative impacts on some of the most innovative companies in the world.
The Fatal Flaw of Pillar Two
Pillar Two, the international global minimum tax agreement, has a considerable chance of failing and may ultimately allow the same problems it was designed to address.
6 min read
The Impact of GILTI, FDII, and BEAT
The Tax Cuts and Jobs Act of 2017 (TCJA) reformed the U.S. system for taxing international corporate income. Understanding the impact of TCJA’s international provisions thus far can help lawmakers consider how to approach international tax policy in the coming years.
30 min read
Weeding the Garden of International Tax
Simplifying international tax rules will not solve all the challenges that stand in the way of healthy cross-border investment, but eliminating unnecessary provisions would be a positive pivot relative to the trajectory of recent years. It’s high time that policymakers stopped pursuing ever more complex rules and started the hard work of simplification.
6 min readAll Related Articles
Tax Files under New Council of EU Presidency: Belgium
In such a determinant semester for Europe, principled tax policy can be an important tool for a more competitive European Union.
5 min read
What’s Next for Tax Competition?
The rules of tax competition are changing with the recent agreement on a global minimum tax and other changes to tax rules around the world, but that does not mean the contest is over.
5 min read
Assessing the EU Tax Observatory’s View on Profit Shifting and the Global Minimum Tax
The EU Tax Observatory has taken an extreme view in assessing the global minimum tax. The rules were not meant to immediately reduce the stock of shifted profits or align profitability levels more closely with employment costs. The rules do change incentives for multinationals, but profits may continue to remain in low-tax jurisdictions for many years.
6 min read
CCCTB vs. BEFIT: How Have the Proposals Changed?
If the EU is going to harmonize its tax base, it should do so in a way that increases the efficiency and competitiveness of tax policy for the EU as a whole, and not just seek out the lowest common denominator.
5 min read
Five Takeaways from the New Pillar One Documents
The OECD recently released a trove of new documents on a draft multilateral tax treaty. The U.S. Treasury has opened a 60-day consultation period for the proposal and is requesting public review and input.
7 min read
Anti-Avoidance Policies in a Pillar Two World
The global minimum tax agreement known as Pillar Two is intended to curb profit shifting. However, OECD countries already have a variety of mechanisms in place that seek to prevent base erosion and profit shifting by multinational corporations.
40 min read
Select Country-Level Revenue Estimates for Pillar Two
Pillar Two implementation is underway in many jurisdictions, and many governments are aiming to get their proposals approved before the end of 2023. However, estimating Pillar Two’s impact on government revenue is proving difficult. As a result, only a few countries have publicly presented their findings.
7 min read
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.
Tax Trends in European Countries
In recent years, European countries have undertaken a series of tax reforms designed to maintain tax revenue levels while protecting households and businesses from high inflation.
8 min read
BEFIT: One-Stop-Shop or One-More-Stop?
On 12 September, the European Commission released a proposal called “Business in Europe: Framework for Income Taxation” (BEFIT) and two associated proposals on transfer pricing and a Head of Office tax system.
6 min read
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.
7 min read
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.
7 min read
Risks to the U.S. Tax Base from Pillar Two
A growing international tax agreement known as Pillar Two presents two new threats to the U.S. tax base: potential lost revenue and limitations on Congress’s ability to set its own tax policy.
39 min read
How Bermuda’s New Corporate Income Tax Could Negatively Impact Some OECD Member States
Bermuda, long celebrated for its pristine beaches and offshore financial services, is embarking on a journey to recalibrate its tax mix. Spurred by the OECD’s Pillar Two initiative, the island will introduce its first-ever corporate income tax in 2025.
4 min read
Global Tax Tug of War: Comparing the UN and OECD Approaches
The United Nations (UN) is preparing to flex its muscles on international tax policy. Several developing countries say the OECD’s approach favors richer countries at their expense, and the UN hopes to fix this.
5 min read
Another Digital Services Tax in Sight
Canada is planning to join the club of countries that, in the past 3 years, introduced a digital services tax (DST) despite U.S. opposition and concerns expressed by Canadian businesses.
4 min read
Blog
Short FormWhat You Need to Know about the Global Tax Deal
The technical rules that were once solely the province of tax wonks in D.C. and Paris are being brought out into the public sphere.
5 min read
Weeding the Garden of International Tax
Simplifying international tax rules will not solve all the challenges that stand in the way of healthy cross-border investment, but eliminating unnecessary provisions would be a positive pivot relative to the trajectory of recent years. It’s high time that policymakers stopped pursuing ever more complex rules and started the hard work of simplification.
6 min read
A Mis-STEP for the European Union: The New Subsidy Race to the Bottom
Enhancing the European Union’s competitiveness is necessary, but the European Commission’s latest attempt is the wrong approach.
4 min read
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.
6 min read