Skip to content

International Proposals

All Related Articles

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

Time for an Updated Impact Assessment of the Global Tax Deal

Treasury Secretary Janet Yellen offered estimates from the EU Tax Observatory as evidence that the Polish government would benefit from supporting the global tax deal. Unfortunately, evidence was, at best, out of date.

2 min read
Biden global minimum tax OECD Pillar Two Blueprint Biden international tax proposal GILTI cross-border investment profit shifting base erosion rules G7 tax and G7 global minimum tax deal. Some questions for global tax reform proposals and negotiations US

Which Global Minimum Tax Will We Get?

Over the course of the last year, it has become clear that Democratic lawmakers want to change U.S. international tax rules. However, as proposals have been debated in recent months, there are clear divides between U.S. proposals and the global minimum tax rules.

5 min read
global tax deal oecd tax deal sales based formulary apportionment oecd pillar one and oecd pillar two global tax agreement

Rushing Headlong into Formulary Apportionment

Complex tax policies that work well “in theory” can often have a hard time when the rubber meets the road. One instance of this is the challenge that the OECD has created for itself with the global tax deal, also fondly known as Pillar 1 and Pillar 2.

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

What Do Global Minimum Tax Rules Mean for Corporate Tax Policies?

The new OECD global minimum tax rules are complex, and some countries may opt to put them in place on top of preexisting rules for taxing multinational companies. However, countries should also consider ways to reform their existing rules in response to the minimum tax.

7 min read
Analysis of the Cost-of-Living Refund Act of 2019 Sherrod Brown Ro Khanna, EITC expansion low-income credit

How Heavily Taxed Are U.S. Multinationals?

In general, the effective tax rates on the foreign profits of U.S. multinationals are not that low relative to the U.S. tax rate, contrary to popular rhetoric.

7 min read
Ireland consultation on OECD international tax proposals ,Tax Foundation Response to Ireland Department of Finance Consultation Document: Consultation on OECD International Tax Proposals

Tax Foundation Response to Ireland Department of Finance Consultation Document: Consultation on OECD International Tax Proposals

The recent effort to change international tax rules has been one of significant contradictions. The proposals have been driven by arguments about the need to raise additional revenues, to stabilize corporate tax rates, or to prevent offshoring. However, upon closer examination, these three arguments fail to capture what is occurring.

Ways & means tax proposal seeks to combat extraterritorial taxes and discriminatory taxes Global minimum tax revenue OECD Pillar Two revenue OECD impact assessment OECD Pillar One tax Pillar one amount a Biden interest limitation Biden interest deduction rule Biden interest expense limitation Business interest expense limitation Democrat Senate international tax overhaul discussion draft legislation (Wyden Brown Warner international tax overhaul) or Sen Wyden international tax plan,

Tax Foundation Comments on the Wyden, Warner, Brown Discussion Draft

The proposed restructuring of the GILTI and FDII regimes makes several changes to the tax base that are largely offsetting, leaving virtually all the revenue potential to be determined by the tax rates on GILTI and FDII and the haircuts on foreign tax credits. Lawmakers should carefully weigh the trade-offs between higher tax revenues and competitiveness.

global minimum tax comparison international tax proposals about profit shifting Biden international tax Learning from Europe and America’s Shared Gross Receipts Tax Experience , Gross receipts taxes Europe America Gross receipts tax digital tax

International Tax Proposals and Profit Shifting

There are many ways the U.S.’s international tax rules could be changed, reformed, improved, or worsened. Reflexively jacking up taxes on U.S. multinationals does not necessarily accomplish the goal of reducing or eliminating profit shifting, and it would in fact worsen it.

6 min read
Ways & means tax proposal seeks to combat extraterritorial taxes and discriminatory taxes Global minimum tax revenue OECD Pillar Two revenue OECD impact assessment OECD Pillar One tax Pillar one amount a Biden interest limitation Biden interest deduction rule Biden interest expense limitation Business interest expense limitation Democrat Senate international tax overhaul discussion draft legislation (Wyden Brown Warner international tax overhaul) or Sen Wyden international tax plan,

Four Revenue Scores on Options to Change U.S. International Tax Rules

Changes to international tax rules are likely on the way, and it is therefore important for lawmakers to understand how various reform options would impact U.S. tax burdens on multinational companies. Moreover, policymakers should also recognize the need for prudent policies that do not put U.S.-based multinationals at a competitive disadvantage or severely curtail investment and hiring.

9 min read
European and G7 countries and a Comparison of their Cross-Border Effective Average Tax Rates

Carve-ins and Carve-outs: Open Questions for Global Tax Reform

There has been some confusion about how some parts of the recent G7 agreement on new tax rules for multinational companies might work. The new policies would target the largest and most profitable multinationals and bring in a global minimum tax.

5 min read
Biden GILTI Biden global minimum tax Biden US global minimum taxBiden international tax Us corporate tax, US tax, corporate income tax, new investment

Two Important Issues that Must Be Resolved in “Global Tax Reform”

If the U.S. is suggesting a 15 percent effective rate as the minimum acceptable rate for a global agreement, then the tax bases of the various minimum taxes adopted as part of the agreement should be aligned to minimize complexities and unintended consequences.

5 min read
OECD Pillar 1 Amount A proposal OECD Secretariat, OECD unified approach pillar 1, OECD pillar 1, OECD international tax, OECD unified approach digital tax, OECD multinational businesses, OECD digital tax

Recent Analysis Explores Pillar 1 Risks and the Potential for Disputes

As countries move closer to agreement on how the OECD Pillar 1 Amount A will work and which companies will be impacted by it, it is incredibly important for policymakers to continue to evaluate not just the intended effects but also the potential unintended consequences.

6 min read