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Global Intangible Low Tax Income (GILTI)

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One Big Beautiful Bill Pros Cons

The Good, the Bad, and the Ugly in the One Big Beautiful Bill Act

The One Big Beautiful Bill Act makes many of the individual tax cuts and reforms of the TCJA permanent. It improves upon the TCJA by making expensing for R&D and equipment permanent. However, for the most part, it does not include further structural reforms, and instead introduces many new, narrow tax breaks to the code, adding complexity and raising revenue costs.

7 min read
State Implications of the GILTI to NCTI Conversion The One, Big, Beautiful Bill’s (OBBB) changes to the taxation of international income

State Implications of the GILTI to NCTI Conversion

The One Big Beautiful Bill’s changes to the taxation of international income have surprising implications for state codes, yielding tax increases and a revised tax base that, through quirks of state incorporation, bears very little resemblance to the federal base and almost nothing of its purpose.

10 min read
Response to OECD Consultation on BEPS 1.0 Base Erosion and Profit Shifting

Response to OECD Consultation on BEPS 1.0

The BEPS project’s 15 actions were decisive responses to real problems in cross-border taxation, offering real benefits but also real costs. A decade of implementation experience has revealed a critical side effect: sharply higher compliance costs for both tax administrations and the business community.

qbai exemption, one big beautiful bill, fdii and gilti

A Partial Defense of the QBAI Exclusion

Lawmakers should consider maintaining QBAI and applying the several billion dollars from the Senate’s change toward other pro-growth international tax reforms instead.

6 min read
illinois budget, tax on gilti, business tax increase

Illinois Policymakers Should Think Twice Before Taxing GILTI

If Illinois’ budget is enacted as-is, Illinois will newly tax 50 percent of Global Intangible Low-Taxed Income (GILTI) as of tax year 2025, retroactively increasing tax burdens for US businesses and further hindering Illinois’ business tax competitiveness.

7 min read
global tax agreement global tax deal OECD global minimum tax rules corporate minimum tax rules Secretariat Proposal, OECD Public Consultation Document, Unified Approach under pillar one profit shifting definition tax planning and avoidance foreign direct investment FDI global tax deal impact of global tax agreement OECD international tax proposal OECD global tax deal anniversary international tax agenda congress us Biden build back better global minimum tax

The Latest on the Global Tax Agreement

The agreement represents a major change for tax competition, and many countries will be rethinking their tax policies for multinationals. If there is no agreement on changes to Pillar Two or digital services taxes, retaliatory American tariffs could be on the horizon.

8 min read
Tax Policy and the US Economy Enhancements to Our Tax Foundation Modeling Framework

Tax Policy and the US Economy: Enhancements to Our Modeling Framework

The Tax Foundation models tax policy using our proprietary Taxes and Growth model, illustrating the economic, revenue, and distributional impacts of different changes to the federal tax code. We’ve recently implemented improvements to the model that have been underway for the past several years, and we will be detailing them further in our forthcoming model methodology update.

4 min read
Trump Global Minimum Tax Order

Five Things to Know About Trump’s Global Minimum Tax Order

This week, the incoming Trump administration issued a day-one executive order on the global minimum tax agreement known as Pillar Two, which seeks to ensure multinational corporations pay at least 15 percent in income tax.

6 min read
Kamala Harris Tax Plan 2024 Details Analysis

Kamala Harris Tax Plan Ideas: Details and Analysis

On tax policy, Harris carries forward much of President Biden’s FY 2025 budget, including higher taxes aimed at businesses and high earners. She would also further expand the child tax credit (CTC) and various other tax credits and incentives while exempting tips from income tax.  

17 min read
GILTI Tax Treatment by State, 2024 GILTI state tax rates

GILTI Tax Treatment by State, 2024

States that tax GILTI increase filing complexity, drive up the cost of tax compliance, and introduce unnecessary economic uncertainty and legal risk. 21 states and DC continue to tax GILTI despite these challenges.

6 min read
Gov Tim Walz tax policies

Gov. Tim Walz Raised Taxes as Most Governors Cut Them

Gov. Walz’s tax policy record is notable because of how much it contrasts with broader national trends. In recent years, most governors have championed tax cuts. Walz, rare among his peers, chose tax increases.

5 min read
Puerto Rico Tax Competitiveness and Pillar Two Global Tax Deal

Puerto Rican Competitiveness and Pillar Two

Puerto Rico, a US territory with a limited ability to set its own tax policies, will be the first part of the US to be substantially affected by Pillar Two, the global tax agreement that seeks to establish a 15 percent minimum tax rate on corporate income.

17 min read