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International Tax Reform Options, GILTI

Pleading GILTI: A Guide to the Complicated World of Global Intangible Low Tax Income

On this episode of The Deduction, we speak with Pam Olson, Tax Foundation Board Member and Consultant on Tax Policy Services at PwC, about the tax on Global Intangible Low Tax Income, or “GILTI.” In 2017, GILTI was implemented as a minimum tax designed to disincentivize U.S. companies from shifting profits overseas, but it doesn’t work how drafters intended, and now President Biden has proposed doubling it.

Wyden 199a pass-through deduction proposal Democrats proposed to expand child tax credit as part of covid relief package. Analysis of the “SALT Act” state and local tax deduction cap, Restoring Tax Fairness to States and Localities Act, SALT cap repeal, eliminate SALT cap

Tax Policy Ideas in the Republican Study Committee Budget

While much of the tax policy now under debate aims to increase the tax burden on businesses, several policies in the newly released Republican Study Committee (RSC) budget for Fiscal Year 2022 focus on reducing the tax code’s barriers to investment and saving.

3 min read
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.

5 min read
Financing Additional Infrastructure Spending with Corporate Tax Increases Would Stunt Economic Growth Biden Infrastructure plan American Jobs Plan new infrastructure $1 trillion in additional infrastructure

Financing Infrastructure Spending with Corporate Tax Increases Would Stunt Economic Growth

The Biden administration’s American Jobs Plan proposal to fund infrastructure spending relies on a bet that the benefits outweigh the costs of a higher corporate tax burden. Using the Tax Foundation model, we find that this trade-off is a bad one for the U.S. economy, resulting in reduced GDP, less capital investment, fewer jobs, and lower wages.

3 min read
Australia budget 2021 to 2022 Australia budget tax proposals and Australia tax proposals in new budget lessons from down under

Tax Policy Lessons from Down Under

This week the Australian government released its latest budget proposal and two policies that stand out in its fiscal response to the pandemic should be helpful as the economic engine of the country turns back on. The first is full expensing for some investments and the second is the introduction of a loss carryback provision. The new budget takes both these temporary policies and extends them into 2023.

2 min read
LIFO tax treatment of inventory LIFO repeal US supply chain resiliency Biden small business taxes Biden tax plan small business impact Investments in long-lived assets, such as structures, must be deducted over long cost recovery periods: up to 27.5 years (for residential buildings) or 39 years (for nonresidential buildings), cost recovery of buildings.

Many Small Businesses Could Be Impacted by Biden Corporate Tax Proposals

Policymakers should recognize that corporate tax hikes will not only impact large firms, but many smaller and younger firms as well. Considering that many of these smaller firms are significant contributors to net job growth, raising corporate taxes at this time would not be conducive for a speedy economic recovery.

2 min read
Denmark has the highest average tax burden on capital income in Europe Taxing Capital Income Comparative Study

Taxing Capital – An International Comparison

The taxation of capital—at both the individual and the corporate level—is much debated and affects economic growth by lowering the incentives to save and invest.

6 min read
US Treasury state tax cuts limitation rule American Rescue Plan Act state and local fiscal recovery funds American Rescue Plan state tax cuts rule

Treasury Rule on State Tax Cuts Limitation Raises New Questions

Today, the U.S. Treasury issued an interim final rule on the $350 billion in State and Local Fiscal Recovery Funds provided under the American Rescue Plan Act (ARPA). The proposed rule resolves several important questions but continues to involve the federal government in state finances at an extraordinary level.

7 min read
State digital taxes and state digital tax proposals, digital advertising tax proposals

States Consider Digital Taxes Amidst Conflicting Rationales

Digital advertising, social media, and data tax proposals have been introduced in nine states following enactment of Maryland’s digital advertising tax, which has since been postponed a year due to administrative and legal challenges.

14 min read
OECD Pillar 1 Amount A proposal OECD Secretariat, OECD unified approach pillar 1, OECD pillar 1, OECD international tax, OECD unified approach digital tax, OECD multinational businesses, OECD digital tax

Recent Analysis Explores Pillar 1 Risks and the Potential for Disputes

As countries move closer to agreement on how the OECD Pillar 1 Amount A will work and which companies will be impacted by it, it is incredibly important for policymakers to continue to evaluate not just the intended effects but also the potential unintended consequences.

6 min read
Location Matters 2021 State Tax Competitiveness Tax Incentives Mature Firms Rankings

What Location Matters Can Tell Us About State Tax Competitiveness

Location Matters is an account of tax complexity and the ways that tax structure affect competitiveness. For policymakers, it represents an opportunity to explore the seemingly more arcane tax provisions that can have a significant impact on business tax burdens, and to discover how their tax code—often completely by accident—picks winners and losers.

4 min read
2022 state tax resource center offers leading 2022 state tax resources and 2022 state tax policy resources

Location Matters 2021: The State Tax Costs of Doing Business

A landmark comparison of corporate tax costs in all 50 states, Location Matters provides a comprehensive calculation of real-world tax burdens, going beyond headline rates to demonstrate how tax codes impact businesses and offering policymakers a road map to improvement.

8 min read