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Taxation of Multinational Businesses

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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.

European Digital Services Taxes DST State of Play

Digital Services Taxes State of Play

Policymakers continue to debate international tax rules after the US gained agreement on a new approach at the G7 that could result in US anti-avoidance policies existing side-by-side with the global minimum tax.

4 min read
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
whats in the big beautiful bill tax plan

The One Big Beautiful Tax Bill: What’s In It, What’s Out

Congress is racing to pass the One Big Beautiful Tax Bill before the July 4 deadline. In this episode, Kyle Hulehan and Erica York break down what just happened over the weekend, what’s actually in the bill, and what comes next as the House and Senate try to reconcile their differences.

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
Improving Tax Treatment of R&D Would Boost Productivity and Growth US Research and Development Tax Treatment Trump Tax Cuts and TCJA Extension and Reform

Improving Tax Treatment of R&D Would Boost Productivity and Growth

As Congress debates expensing and other policies impacting business investment, lawmakers should consider the importance of business investment in research and development (R&D) as a driver for economic growth. Recent studies suggest that the economic benefits of R&D spending are even greater than previously understood.

7 min read
2025 Digital Tax Europe Data including Digital Services Taxes in Europe

Digital Services Taxes in Europe, 2025

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

The Global Tax Deal, Tax Cuts, and Tariffs—5 Major Tax Debates

What are the biggest tax stories shaping policy today—and what do they mean for you? In our 100th episode, we break down the five biggest tax stories, from the global tax deal to the looming expiration of the Tax Cuts and Jobs Act. 

Trump Global Tax Deal Approach 2025

Trump Must Approach Global Tax Deal with Scalpels, Not Buzzsaws

President Donald Trump surprised many in the tax community by making the global tax deal a day one issue. His Jan. 20 memorandum gave his Treasury secretary 60 days to recommend interactions with tax treaties and possible protective measures to ensure the minimum tax rules have no force or effect in the US.