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Taxation of Multinational Businesses

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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
International tax rules, International Tax rules House Democrats' covid-19 relief proposal

An “Interest”ing Tax Hike in the COVID-19 Relief Proposal

As the House Ways and Means Committee continues working on the latest round of fiscal relief amid the pandemic, one curious provision in the legislation is a tax hike on multinational companies. One section of the legislation would repeal a provision in current law that allows U.S. multinationals to choose to allocate their interest costs on a worldwide basis (more on that in a moment).

4 min read
EU tax research The European Commission and the Taxation of the Digital Economy EU digital levy

The European Commission and the Taxation of the Digital Economy

The consultation on the EU’s digital levy provides an opportunity for policymakers and taxpayers to reflect on the underlying issues of digital taxation and potential consequences from a digital levy. Unless the EU digital levy is designed with an OECD agreement in mind, it is likely to cause more uncertainty in cross-border tax policy.

12 min read
utpr pillar two us tax base oecd global minimum tax ways and means jason smith

Corporate Tax Rates Around the World

What is driving the downward trend in corporate tax rates and will it continue? Is it truly a race to the bottom? Why do corporate tax rates matter in the first place? How does the U.S. rate compare and could that change in the coming years?

Biden carbon tax corporate tax trade offs

Two Roads Diverge in the OECD’s Impact Assessment

The difference that the OECD presents between the potential impact in the context of agreement compared to a harmful tax and trade war should show policymakers the value of continuing multilateral discussions.

6 min read
OECD BEPS Higher Corporate Tax Revenues Globally Despite Lower Tax Rates

Pillars, Blueprints, an Impact Assessment, and Construction Delays

The OECD released blueprints for proposals on changing international tax rules alongside an impact assessment based on the overall design of the proposals. While the blueprints cover proposals both for changing where large multinationals owe corporate tax and designing a global minimum tax, there are still many unanswered questions. In the meantime, other digital tax proposals are moving forward and have the potential to result in a harmful tax and trade war.

4 min read
Thin-capitalization rules, Thin-cap rules in Europe

Thin-Cap Rules in Europe

To discourage a certain form of international debt shifting, many countries have implemented so-called thin-capitalization rules (thin-cap rules), which limit the amount of interest a multinational business can deduct for tax purposes.

4 min read
Tax Cuts and Jobs Act offshoring OECD BEPS project, OECD consultation document, OECD multinationals, Consumption tax policies in OECD countries, Consumption taxes in OECD countries

Summary of the OECD’s Impact Assessment on Pillar 1 and Pillar 2

The OECD presented its preliminary impact assessment on the Pillar 1 and Pillar 2 proposals. The impact assessment includes estimated revenue and investment effects presented at a country group level (low-, middle- and high-income countries and investment hubs). The OECD estimates global corporate income tax revenues to increase by 4 percent if both pillars get implemented, equaling $100 billion annually.

4 min read