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
22 of the 27 EU Member States have implemented both the income inclusion rule and the qualified domestic minimum top-up tax in 2025.
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
While there are many factors that affect a country’s economic performance, taxes play an important role. A well-structured tax code is easy for taxpayers to comply with and can promote economic development while raising sufficient revenue for a government’s priorities.
93 min read
Since digital services taxes deliver limited revenue, shift the burden to European consumers, and risk provoking trade disputes, it’s time for policymakers to rethink their approach.
Massachusetts lawmakers should look for opportunities to reform the tax code, revamp the state’s competitiveness, and stem the tide of outmigration. This bill, by contrast, would double down on the economically uncompetitive features of the Commonwealth’s existing tax code. Aggressively expanding NCTI inclusion is not productive or competitive.
5 min read
The reality is that the US is the winner from globalization, the capital of the world. Let’s keep it that way.
Senator Bernie Moreno’s (R-OH) Halting International Relocation of Employment (HIRE) Act is a proposal to discourage US companies from outsourcing jobs and services abroad for products consumed by Americans.
7 min read
Instead of getting stuck in a reactionary posture, European countries should simply aim for competitiveness, and the EU can support that work with stronger, more stable trade relationships.
Rather than returning to a world of retaliatory tax measures and transatlantic disputes, the OECD should continue to decrease the compliance costs of Pillar Two by simplifying the rules to reduce any possible risk that the US has a compliance cost advantage and working with G7 countries on a side-by-side solution.
6 min read
Sean Bray interviews Dr. Eva Eberhartinger, professor of business taxation at WU Vienna University of Economics and Business, about the future of the EU tax mix.
8 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.
Sean Bray interviews Dr. Irma Mosquera Valderrama, Full Professor of Tax Governance at Leiden Law School (Leiden University) and EU Jean Monnet Chair Holder on EU Tax Governance about the EU tax mix.
24 min read
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
We estimate the OBBBA will reduce federal taxes on average for individual taxpayers in every state. Across all individual tax filers throughout the US, the average tax cut per taxpayer will be over $3,700 in 2026.
4 min read
The OBBBA moved the US international tax system in the right direction on several fronts. However, some of the changes, while encouraging certain domestic activity and exports, may harm physical activity abroad that supports US competitiveness and domestic activity.
8 min read
For Congress, work on the One Big Beautiful Bill Act is done. But in state capitols, the work has not yet begun. Many of the tax changes in the federal reconciliation act flow through to state tax codes—automatically in some states, and subject to an update in states’ Internal Revenue Code conformity date in others.
39 min read
Even when international relations are frayed, there is value in finding ways to combat corporate profit shifting while also fostering a healthy commercial atmosphere and positive trade relations.
7 min read
Our experts explain how this major tax legislation may affect you and how policymakers can better improve the tax code.
24 min read