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Taxation of Multinational Businesses Archive

USICA, Competes Act, Corporate Tax Comparison

TweetShareSharePin0 Shares Key Findings Federal policymakers are debating a legislative package focused on boosting U.S. competitiveness vis-a-vis China; however, it currently contains little to no improvements to the U.S. tax code. The existing U.S. tax code is biased against capital investment and it is scheduled to worsen over the next decade. The tax bias against

Pillar Two: Global Minimum Tax Model Rules

TweetShareSharePin0 Shares Everyone loves accounting, right? You have debits and credits that change the balance of assets, liabilities, and equity on the balance sheet and report cash flows and accruals on the income statement. The rules are complex. To make matters worse, the accounting rules for tax are different than for financial accounting used to

A Regulatory Tax Hike on US Multinationals

TweetShareSharePin0 Shares Throughout the first year of the Biden administration, one tax policy theme was consistent. The President and Treasury Secretary Janet Yellen were focused on increasing the tax burden on U.S. companies—particularly multinational companies.  As Secretary Yellen put it last year, “It is about making sure that governments have stable tax systems that raise

Global Minimum Tax & Build Back Better Revenue

TweetShareSharePin0 Shares The global minimum tax has upended many conversations about international tax policy, including in the United States. The goal of the policy is to set a worldwide 15 percent minimum effective tax rate on corporate profits and enforce it through a set of interconnected rules. If enough countries adopt those rules, then even

Formulary Apportionment and the OECD Tax Deal

TweetShareSharePin0 Shares One of the greatest challenges of lawmaking is recognizing when a beautiful theory must succumb to an ugly fact. The purity of conceptual policymaking must take the real world into account and acknowledge that things that work well “in theory” sometimes fail spectacularly to meet expectations “in practice.” It would be wonderful if

10 Tax Reforms for Economic Growth and Opportunity

TweetShareSharePin0 Shares Key Findings The waning pandemic and robust economic recovery have come with many benefits—plentiful jobs and fast-growing (nominal) incomes—but also serious challenges such as high and rising inflation. Rather than pushing for more fiscal stimulus or leaving it to the Federal Reserve to handle inflation through higher interest rates, policymakers should focus on

US Global Minimum Tax Build Back Better Considerations

TweetShareSharePin0 Shares The Build Back Better legislative package includes both tax hikes and tax cuts, which contain two contrasting tax policy narratives. Tax hikes include corporate tax increases on foreign income and a new 15 percent domestic minimum tax, and green energy tax incentives provide a tax cut. Policymakers also sought to protect some pre-existing tax

How Would the Ways and Means Proposal Affect Profit Shifting?

TweetShareSharePin0 Shares Recent proposals to increase the effective tax rates (ETRs) faced by multinationals rely on the argument that these firms achieve artificially low tax rates by shifting profits to foreign tax havens and other low-tax countries. By raising the tax rates on the foreign income of U.S. multinationals, these proposals would supposedly reduce profit
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