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Taxation of Multinational Businesses

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Foreign Research and Development, OBBBA Full Expensing

The Hidden Costs of Foreign R&D Amortization

Foreign R&D generally complements domestic innovation rather than substituting for it, so penalizing foreign R&D weakens US firms in cross-border mergers and acquisitions and in domestic production that depends on global scale.

7 min read
company disclosure; company tax disclosure tax disclosure tax transparency country by country reporting cbcr

Three Questions to Ask About New Tax Transparency Regimes

The new data disclosures will draw significant attention in 2026 and beyond. However, because the data is rooted in financial accounting concepts, affected by timing issues, and shaped by inconsistent reporting regimes, it is poorly suited for drawing strong conclusions about tax policy or corporate behavior.

7 min read
Digital Services Taxes and the European Budget

Testimony: Are Digital Services Taxes a Viable Solution for the EU Budget?

Digital services taxes address a real concern—the need to adapt taxation to the digital economy—but they are not the right solution. They raise limited revenue, are often passed on to consumers rather than large digital firms, create economic distortions, increase complexity and compliance costs, negatively impact innovation and competitiveness, and risk international retaliation.

UN digital tax negotiations with European countries

What Europe’s UN Tax Turn Means for Multinationals

Europe’s turn toward the UN is ultimately not a sign that governments are ready to resolve fundamental disputes over taxing rights. If anything, international cooperation on the goal that matters most—fair treatment of cross-border trade—is crumbling.

Digital Services Taxes in Europe, 2026

Digital Services Taxes in Europe, 2026

Currently, about half of all European OECD countries have either announced, proposed, or implemented a digital services tax. Because these taxes mainly impact US companies and are thus perceived as discriminatory, the US responded with retaliatory tariff threats.

5 min read
California Worldwide Combined Reporting, CA Corporate Income Taxation

California’s Mandatory Worldwide Combined Reporting Proposal Is a Mistake

California lawmakers are considering mandating worldwide combined reporting, bringing back a policy the state abandoned in the 1980s due to strong pushback from international trading partners and the federal government. The policy failed to work as intended then and doesn’t make any better sense now.

8 min read
Global Tax Agreement, Pillar Two Implementation, Side-by-Side Agreement

Side-by-Side Implementation Is a Good Start, but It’s Just the Beginning

The side-by-side agreement is an important step in trans-Atlantic economic relations, however, there is more work to be done—on both sides of the Atlantic. If there’s a downside to the side-by-side agreement, it’s the risk of locking in mediocre tax policy choices for the long run.

2025 European Tax Policy Scorecard

2025 European Tax Policy Scorecard

The variety of approaches to taxation among European countries creates a need to evaluate these systems relative to each other. For that purpose, we have developed the European Tax Policy Scorecard—a relative comparison of European countries’ tax systems.

55 min read
Biden CHIPS and Biden Inflation Reduction Act analysis of Biden business investment and US investment research

Trump Tax Policy Shift Toward Stability Must Stay the Course

The Trump administration has rightly shifted its focus from pursuing legislative changes to implementing new permanent rules. But in this shift, it’s crucial that the White House doesn’t lose focus on the larger task at hand.

2025 Tax Review | What OBBBA Changed, the Impact of Tariffs, and What’s Next

In this episode, we break down what the OBBBA did, walk through our projections, and zoom out to other defining fights of 2025: Trump’s “Liberation Day” tariffs, the Supreme Court challenge over presidential tariff power, and the growing wave of property tax revolts across the states. 

GILTI to NCTI, State Tax Codes Decouple

Some States Will Tax NCTI Despite Prior Votes to Exempt International Income

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
International Tax Competitiveness Index 2025 Global Tax Rankings by Country

International Tax Competitiveness Index 2025

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
EU digital services taxes testimony tax foundation European Union EU flag

Testimony: Digital Services Taxes in the European Union

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.