About | HeinOnline Law Journal Library | HeinOnline Law Journal Library | HeinOnline
LOG IN
LOG IN

1 Alan Cole, The Impact of GILTI, FDII, and BEAT 1 (2024)

handle is hein.taxfoundation/imptogl0001 and id is 1 raw text is: *.TAX FOUNDATION The Impact of GILTI, FDII, and BEAT Alan Cole Senior Economist January 2024 Key Findings • The Tax Cuts and Jobs Act of 2017 (TCJA) reformed the U.S. system for taxing international corporate income. Understanding the impact of TCJA's international provisions thus far can help lawmakers consider how to approach international tax policy in the coming years. • International tax policy must balance competing objectives, such as maximizing revenue and growth while minimizing profit shifting and complexity. • The TCJA's international changes-a transition to a territorial system with worldwide elements, and some anti-base-erosion measures-were an attempt to balance those competing objectives. • The TCJA's international system's global minimum tax; known as GILTI, raises substantial revenue, but it may lose much of its revenue as countries work to comply with Pillar Two. • The TCJA's incentive to keep highly mobile profits in the U.S., known as FDII, has been somewhat suc- cessful in curbing profit shifting. • A rule known as BEAT, which disallows the overuse of cross-border tax deductions commonly associ- ated with profit shifting as measured by accounting data, may not be as effective as projected. • Reformers should build on what these provisions got right and modify them where they fail or where they become incompatible with international tax developments. The Tax Foundation is the world's leading nonpartisan tax policy 501(c)(3) nonprofit. For over 80 years, our mission has remained the same: to improve lives through tax policies that lead to greater economic growth and opportunity. TAX FOUNDATION 1325 G STREET, NW, SUITE 950, WASHINGTON, DC 20005 202-464-6200 1 taxfoundation.org

What Is HeinOnline?

HeinOnline is a subscription-based resource containing thousands of academic and legal journals from inception; complete coverage of government documents such as U.S. Statutes at Large, U.S. Code, Federal Register, Code of Federal Regulations, U.S. Reports, and much more. Documents are image-based, fully searchable PDFs with the authority of print combined with the accessibility of a user-friendly and powerful database. For more information, request a quote or trial for your organization below.



Contact us for annual subscription options:

Contact Us

Already a HeinOnline Subscriber?

Log In

profiles profiles most