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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 readJoin Us for a Free “State Tax Policy Boot Camp”
The Tax Foundation’s “State Tax Policy Boot Camp,” is ideal for anyone interested in gaining a better understanding of state taxation.
2 min readAn “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 readThe 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 readCorporate 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?
Comparing Europe’s Tax Systems: International Tax Rules
International tax rules define how income earned abroad and by foreign entities are taxed domestically, making them an important element of a country’s tax code.
3 min readTwo 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 readPillars, 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 readBiden’s Plan to Address Offshoring Comes with Contradictions
If the goal of the Biden campaign is to bring new investment and jobs to the U.S., it is doubtful that these new tax rules will contribute to that goal.
4 min readThin-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 readChallenges for Transfer Pricing in an Economic Downturn
Transfer pricing rules are under stress given the current economic crisis. The OECD should provide transfer pricing guidance during the coronavirus crisis.
13 min readSummary 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 readComparison of Cross-Border Effective Average Tax Rates in Europe and G7 Countries
As policymakers consider ways to facilitate investment, effective average tax rates provide a valuable perspective on where burdens on those activities are high and where they are low.
16 min read