Several states have decoupled from GILTI by name rather than statutory citation. Lawmakers in those states should amend these statutes to ensure that their tax code does not accidentally incorporate a much more aggressive tax on international income than the tax from which they previously decoupled.
6 min read
Due to the incentive for jurisdictions to implement a qualified domestic minimum top-up tax (QDMTT), Pillar Two leaves a geographic asymmetry. Additional tax revenues would predominantly accrue to low-tax jurisdictions, with high tax jurisdictions receiving little to no increase.
2 min read
Creative destruction—coined by famed economist Joseph Schumpeter—is the idea that new innovations disrupt and “destroy” existing economic structures as they create better and more efficient products and processes.
4 min read
New evidence shows the scale and distribution of compliance costs for EU firms affected by Pillar Two, i.e., the “Global Minimum Tax.”
6 min read
The US has a reasonably robust system for containing profit shifting; it is in effect already working towards the Pillar Two goals. Its negotiating posture is in many cases curbing unreasonable sidetracks, not undermining the whole project.
The agreement represents a major change for tax competition as well, and many countries will rethink their tax policies for multinationals. However, the US will continue to chart its own course, and other countries may prefer to do the same, depending on the final outcome of the G7 statement.
8 min read
The One Big Beautiful Bill’s changes to the taxation of international income have surprising implications for state codes, yielding tax increases and a revised tax base that, through quirks of state incorporation, bears very little resemblance to the federal base and almost nothing of its purpose.
10 min read
The BEPS project’s 15 actions were decisive responses to real problems in cross-border taxation, offering real benefits but also real costs. A decade of implementation experience has revealed a critical side effect: sharply higher compliance costs for both tax administrations and the business community.
Policymakers continue to debate international tax rules after the US gained agreement on a new approach at the G7 that could result in US anti-avoidance policies existing side-by-side with the global minimum tax.
4 min read
While well-designed excise taxes can make society better off, some of the health taxes proposed by the WHO use a pretty façade to cover for policies that fail to deliver their promised benefits.
5 min read
President Donald Trump surprised many in the tax community by making the global tax deal a day one issue. His Jan. 20 memorandum gave his Treasury secretary 60 days to recommend interactions with tax treaties and possible protective measures to ensure the minimum tax rules have no force or effect in the US.
An update to the EU’s Excise Tax Directive that embraces harm reduction principles would save lives and provide a steady stream of revenue to support public health expenditures.
22 min read
Tax legislation in 2025 may have good reason to address international corporate income taxes, because of scheduled changes slated to go into effect or because of international developments like the Pillar Two agreement.
63 min read
This week, the incoming Trump administration issued a day-one executive order on the global minimum tax agreement known as Pillar Two, which seeks to ensure multinational corporations pay at least 15 percent in income tax.
6 min read
Bob Stack, an international tax expert, explores the implications of the EU’s adoption of Pillar Two and the potential for streamlining overlapping policies. He also addresses the issues that the US faces in global tax policy with the upcoming elections.
Pillar Two risks creating a more complex and unfair international tax system. It is inadvertently fostering new, opaque, and complex forms of competition, and policymakers should consider alternative approaches to creating a fairer international tax environment.
4 min read
How does living abroad impact the taxes an American has to pay? Unlike most countries that tax based on residency, the US employs citizenship-based taxation, meaning Americans are taxed on their global income regardless of where they reside.
The global tax deal and Pillar Two are shaking up the tax landscape worldwide, introducing a web of complexity and confusion.
Adopting tax policy based on sound principles like neutrality rather than political expediency is essential for the European Union’s fiscal future.
5 min read
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