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Tax Cuts and Jobs Act (TCJA)

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intellectual property IP tax GILTI FDII global minimum tax Biden tax patent boxes impact business, patent boxes, software, intellectual property tax

The Balancing Act of GILTI and FDII

The tax treatment of intangible assets has come into the spotlight recently with the Biden administration proposing to undo a policy adopted in 2017 to encourage intellectual property (IP) to be located in the U.S.

6 min read
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
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Phasing in a Corporate Rate Hike Would Be the Worst of Both Worlds

The Biden administration has signaled its openness to raising the corporate tax rate, potentially by phasing in an increase over several years. While phasing in a tax increase, as opposed to hiking immediately, may seem like a reasonable middle ground, it would be the worst of both worlds because it provides old investment with a lower rate while penalizing new investment.

2 min read

Evaluating Proposals to Increase the Corporate Tax Rate and Levy a Minimum Tax on Corporate Book Income

President Biden and congressional policymakers have proposed several changes to the corporate income tax, including raising the rate from 21 percent to 28 percent and imposing a 15 percent minimum tax on the book income of large corporations, to raise revenue for new spending programs. Our new modeling analyzes the economic, revenue, and distributional impact of these proposals.

46 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
Build Back Better Act: Details & Analysis of the House Ways and Means Committee Tax Proposals Reconciliation Bill Tax, Biden taxes, Biden tax plan, Biden tax increases

Who Benefits from the State and Local Tax Deduction?

Some lawmakers have expressed interest in repealing the SALT cap, which was originally imposed as part of the Tax Cuts and Jobs Act (TCJA) in late 2017. It is important to understand who benefits from the SALT deduction as it currently exists, and who would benefit from the deduction if the cap were repealed.

6 min read
How Corporate Income is Taxed Twice Double Taxation of Corporate Income in the United States and the OECD savings and investment OECD capital gains tax retirement accounts stock

Double Taxation of Corporate Income in the United States and the OECD

Biden’s proposal to increase the corporate income tax rate and to tax long-term capital gains and qualified dividends at ordinary income tax rates would increase the top integrated tax rate above pre-TCJA levels, making it the highest in the OECD and undercutting American economic competitiveness.

16 min read
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Tax Extenders Hitch a Ride on Omnibus and COVID-19 Relief Deal

Tax extenders are no stranger to hitching a last-minute ride on year-end legislation. This year they made another last-minute appearance, finding a hold in their own division of the 5,593-page bill to fund the government through the fiscal year and provide additional coronavirus relief through March.

2 min read
Permanent Build Back Better middle class tax hike Tax Cuts and Jobs Act, Tax Reform

Outlining a Path for Tax Policy Compromises

While a sweeping tax policy bill is unlikely in the near future, lawmakers may be able to come together on a smaller scale. Pairing better cost recovery on a permanent basis with support for vulnerable households as well as additional pandemic-related relief would help promote a more rapid return to growth and help businesses and households weather the ongoing crisis.

4 min read
Federal tax policy after the 2020 election, upcoming federal tax increases, another round of economic relief

Prospects for Federal Tax Policy After the 2020 Election

President Biden and Congress should concentrate on areas of common ground, finding incremental places to improve the tax code. A bipartisan bill recently introduced to help retirement savings is a good model for what incremental reform may look like.

4 min read
Trump Tax Cuts Benefited Who? Tax Cuts and Jobs Act lowered effective tax rates across income levels, Trump Tax Cuts Middle Class

A Preliminary Look at 2019 Tax Data for Individuals

The latest IRS data continues to illustrate that the net effect of the Tax Cuts and Jobs Act was to reduce effective tax rates across income groups. In 2019, the TCJA again expanded the use of several deductions and credits, made the standard deduction more favorable than itemizing, and lowered taxes for most taxpayers.

4 min read
The Biden Tax Plan Would Rank the U.S. Below Where It Stood Prior to Tax Reform International Tax Competitiveness Index Ranks for 2020 with the U.S. ranks for 2017, 2020, and the Biden tax plan us competitiveness

How Would Biden’s Tax Plan Change the Competitiveness of the U.S. Tax Code?

While the Biden campaign is certainly focused on increasing taxes on U.S. businesses and high-income earners, it is important that policymakers also understand what that reversal might do to U.S. competitiveness, and the competitive global environment in which U.S. companies and U.S. workers operate.

3 min read
us jobs lost during coronavirus, us jobs coronavirus us layoffs, US jobs data, US economy covid-19

Role of the 2017 Tax Reform in the Nascent U.S. Economic Recovery

While there is still plenty of work to be done to get unemployed Americans back to work, the U.S. economy as a whole is now recovering strongly from the pandemic-induced economic downturn, outperforming forecasts from earlier in the year and outperforming most other developed countries.

4 min read
CARES Act, Senate Coronavirus bill, Senate Coronavirus relief, Senate Coronavirus Aid

Reviewing the Commitment to American GROWTH Act

House Republicans recently introduced HR 11, the Commitment to American GROWTH Act, outlining an alternative to Democratic presidential nominee Joe Biden’s tax vision. The proposal would address upcoming expirations of the 2017 Tax Cuts and Jobs Act (TCJA) and create or expand other tax provisions designed to boost domestic investment.

5 min read
The US federal tax system is progressive overall

Congressional Budget Office Releases 2017 Data on Household Income and Tax Burdens

Contrary to the perceptions of some, new data indicate that (1) income earned after taxes and transfers has increased over the past several decades for all income groups; (2) the federal tax system is increasingly progressive; and (3) that system relies heavily on higher earners to raise revenue for government services and means-tested transfers.

3 min read