Minimum taxation in the United States in the context of GloBE

Resource Information

The item Minimum taxation in the United States in the context of GloBE represents a specific, individual, material embodiment of a distinct intellectual or artistic creation found in International Bureau of Fiscal Documentation.
This item is available to borrow from 1 library branch.

Summary: The introduction of the minimum tax in Pillar two of the OECD/G20/Inclusive Forum (IF) framework was generally seen as a response to the US Tax Cuts and Jobs Act (TCJA) of 2017. The TCJA included both a minimum tax on outbound income (the Global Intangible Low-Taxed Income, or ‘GILTI’) and a minimum tax on inbound income (the Base Erosion Anti-Avoidance Tax, or ‘BEAT’). These were seen as the precursors to the Income Inclusion Rule (IIR) and the Under Tax Payments Rule (UTPR). Thus, unlike Pillar one which was perceived as a device to impose more tax on the US digital giants, Pillar two was seen as more consistent with US tax policy. This story is true to some extent, but the relationship between the US and Pillar two is more complicated. Pillar two was the culmination of years of efforts to implement the single tax principle, which has its origins in the 1920s but was not the guiding principle of US tax policy for a long period before the TCJA. Moreover, the TCJA does not fully implement Pillar two, and it is unclear whether the US can in fact do so. In this article, the authors first discuss the relationship between the TCJA and Pillar two, then the possible US responses to Pillar two, and finally what would happen if the US does not implement Pillar two. In general, if Pillar two is not implemented in the US, the tax consequences are likely to be increased double taxation as well as a shift in revenues from the US to foreign jurisdictions

Work

Summary: The introduction of the minimum tax in Pillar two of the OECD/G20/Inclusive Forum (IF) framework was generally seen as a response to the US Tax Cuts and Jobs Act (TCJA) of 2017. The TCJA included both a minimum tax on outbound income (the Global Intangible Low-Taxed Income, or ‘GILTI’) and a minimum tax on inbound income (the Base Erosion Anti-Avoidance Tax, or ‘BEAT’). These were seen as the precursors to the Income Inclusion Rule (IIR) and the Under Tax Payments Rule (UTPR). Thus, unlike Pillar one which was perceived as a device to impose more tax on the US digital giants, Pillar two was seen as more consistent with US tax policy. This story is true to some extent, but the relationship between the US and Pillar two is more complicated. Pillar two was the culmination of years of efforts to implement the single tax principle, which has its origins in the 1920s but was not the guiding principle of US tax policy for a long period before the TCJA. Moreover, the TCJA does not fully implement Pillar two, and it is unclear whether the US can in fact do so. In this article, the authors first discuss the relationship between the TCJA and Pillar two, then the possible US responses to Pillar two, and finally what would happen if the US does not implement Pillar two. In general, if Pillar two is not implemented in the US, the tax consequences are likely to be increased double taxation as well as a shift in revenues from the US to foreign jurisdictions

Citation source: In: Intertax. - Alphen aan den Rijn. - Vol. 50 (2022), no. 10 ; p. 673-677

http://library.link/vocab/creatorName

http://library.link/vocab/subjectName

Visit the Library

IBFD Library AmsterdamBorrow it

Rietlandpark 301, Amsterdam, 1019 DW, NL

52.3736660 4.9336932

Structured data from the Bibframe namespace is licensed under the Creative Commons Attribution 4.0 International License by International Bureau of Fiscal Documentation. Additional terms may apply to data associated with third party namespaces.