The Tax Cuts and Jobs Act (TCJA) in 2017 took a new direction for the treatment of U.S. multinationals. Six significant reforms departed from the old system:
The U.S. no longer has a worldwide tax system for taxing corporate income. But it does not have a truly territorial system either. Instead, the U.S. now has a hybrid system with some worldwide taxation, without deferral, for certain foreign income because of GILTI and Subpart F and a tax on certain cross-border transactions.
Countries participating in the OECD Inclusive Framework’s negotiations on cross-border tax rules hope to reach an agreement by mid-2021. After negotiations stalled somewhat in 2020, there is hope that US Treasury Secretary Janet Yellen’s commitment to reaching an agreement will allow progress to be made this year.
The posts below include our research and analysis of policies related to cross-border tax rules, including Global Intangible Low Tax Income (GILTI), Foreign Derived Intangible Income (FDII), Base Erosion and Anti-abuse Tax (BEAT), and the Global Anti-base Erosion (GloBE) rules in the context of the OECD’s Inclusive Framework on Base Erosion and Profit Shifting (BEPS).
International Tax Rules Primer U.S. Tax Competitiveness Primer GILTI Primer FDII Primer Learn more with TaxEDU
Over the course of the last year, it has become clear that Democratic lawmakers want to change U.S. international tax rules. However, as proposals have been debated in recent months, there are clear divides between U.S. proposals and the global minimum tax rules.
5 min read
Leaders around the world are quickly moving to finalize an agreement on a global minimum tax in 2021, based on the so-called “Pillar Two” proposal from the OECD.
25 min read
The Biden administration’s international tax proposals would impose a 7.7 percent surtax on the foreign profits of U.S. multinationals, resulting in a net increase in profit shifting out of the U.S.
60 min read
The international corporate tax changes in President Biden’s tax plan would increase tax rates on domestic income more than on foreign income, resulting in a net increase in profit shifting out of the US, according to our Multinational Tax Model.
33 min read
Since only U.S. businesses pay the GILTI tax, not foreign businesses, it makes U.S.-based brands less competitive abroad. Whatever its intentions, GILTI is a flawed policy, and doubling down on it will hurt us abroad, and at home.
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
The Tax Cuts and Jobs Act significantly reduced the federal statutory corporate income tax rate. When combined with state and local taxes, it put the U.S.’s corporate tax rate in line with the average among OECD nations.
4 min read
The TCJA is projected to improve the United States’ current ranking from 30th among the 35 Organisation for Economic Co-operation and Development (OECD) countries to 25th, an improvement of five places.
4 min read
Tariffs on washing machines and solar cells, though designed to help U.S. manufacturing and protect consumers, will likely raise prices and distort markets.
3 min read
If enacted, the Tax Cuts and Jobs Act would put the U.S. corporate tax rate more in line with its international peers at 13th highest of 35 OECD countries.
2 min read
The House and Senate have both passed legislation that would overhaul the federal tax code. Learn about the key differences between the two bills.
7 min read
The Senate’s version of the Tax Cuts and Jobs Act (TCJA) includes several important changes to the taxation of multinational corporations.
5 min read
The Senate Tax Cuts and Jobs Act includes hundreds of structural reforms to the tax code. Here is a guide to the eight most important changes.
5 min read
One goal of the House Tax Cuts and Jobs Act is to move international business taxation to a territorial rather than a worldwide system. Here’s how it would work.
7 min read
Considered as a whole, this plan would make the U.S. substantially more competitive, not only due to lower rates but also due to a better tax structure.
2 min read
Hampered by high marginal tax rates and complex business tax rules, the United States again ranks towards the bottom of the pack on our 2017 International Tax Competitiveness Index, placing 30 out of 35 OECD countries.
11 min read
When taking a closer look at the UK’s recent corporate tax reform experiment, it becomes clear that there was significantly more at work than just a simple rate cut. Increasing the effective marginal tax rate on new investments could have had a negative effect on wages, potentially offsetting the positive effects from the corporate rate cut.
4 min read
Republican leadership in the House, Senate, and White House released a framework for a tax proposal that would lower taxes on businesses and individuals and simplify a number of aspects of the federal tax code. Here are the details we know right now.
3 min read
The last time the U.S. reduced its federal corporate income tax rate was in 1986. Since then, countries throughout the world have significantly reduced their rates, leaving the U.S. with the fourth highest statutory corporate tax rate in the world and an overall uncompetitive tax system.
11 min read
