The 2017 Tax Cuts and Jobs Act (TCJA) sharply reduced effective corporate income tax rates on equity-financed US investment. This paper examines the reform’s impact on US inbound foreign direct investment (FDI) and investment in property, plant and equipment (PPE) by foreign-owned US companies....
The Trump administration has announced the broad outlines of a tax reform plan that contains many provisions similar to those in the House GOP tax reform “blueprint” announced last year, but there are fundamental differences in the provisions affecting businesses and investors. While different,...
This report updates and revises the authors’ 2014 proposal to replace the corporate income tax with taxation at ordinary income rates of dividends and net accrued capital gains of American shareholders. The new proposal retains a 15 percent corporate income tax, gives taxable shareholders a...
In a recent Tax Notes article, Shay argued that Treasury could write regulations to reduce the tax incentives for U.S. corporations to expatriate. Rosenthal agrees with Shay and analyzes the legal support for regulations under section 385.
Recently, there has been a spate of corporate inversions, where U.S. multinational corporations have combined with foreign companies, arranging their corporate structure to locate the residence of the resulting corporation in a foreign country with an attractive corporate tax climate. This paper...
In a contribution to the Wall Street Journals MarketWatch Inc., Eric Toder and Alan Viard argue that recent highly publicized tax avoidance transactions by U.S. corporations reflect basic flaws in how we tax the income of multinational corporations, and that proposed reforms that maintain...
In a contribution to The Wall Street Journal's MarketWatch, Eric Toder explains why corporations expatriate from the United States and argues that they will continue to do so until Congress addresses the fundamental flaws in the corporate income tax. He then provides some possible solutions to...
On February 28, 2014, the Urban Institute hosted an invitational conference on what policymakers in the United States can learn from the experience of other countries with territorial systems for taxing the income of their multinational corporations. Participants included academic experts,...
The Impact of the Tax Cuts and Jobs Act on Foreign Investment in the United States
The 2017 Tax Cuts and Jobs Act (TCJA) sharply reduced effective corporate income tax rates on equity-financed US investment. This paper examines the reform’s impact on US inbound foreign direct investment (FDI) and investment in property, plant and equipment (PPE) by foreign-owned US companies....
Neutral Tax Reform with 15 Percent Business Income Tax Rate
The Trump administration has announced the broad outlines of a tax reform plan that contains many provisions similar to those in the House GOP tax reform “blueprint” announced last year, but there are fundamental differences in the provisions affecting businesses and investors. While different,...
A Proposal to Reform the Taxation of Corporate Income
This report updates and revises the authors’ 2014 proposal to replace the corporate income tax with taxation at ordinary income rates of dividends and net accrued capital gains of American shareholders. The new proposal retains a 15 percent corporate income tax, gives taxable shareholders a...
Professor Shay Got It Right: Treasury Can Slow Inversions
In a recent Tax Notes article, Shay argued that Treasury could write regulations to reduce the tax incentives for U.S. corporations to expatriate. Rosenthal agrees with Shay and analyzes the legal support for regulations under section 385.
Corporate Inversions
Recently, there has been a spate of corporate inversions, where U.S. multinational corporations have combined with foreign companies, arranging their corporate structure to locate the residence of the resulting corporation in a foreign country with an attractive corporate tax climate. This paper...
Corporate Tax is Broken and Needs Major Surgery
In a contribution to the Wall Street Journals MarketWatch Inc., Eric Toder and Alan Viard argue that recent highly publicized tax avoidance transactions by U.S. corporations reflect basic flaws in how we tax the income of multinational corporations, and that proposed reforms that maintain...
How To Stop Corporations From Fleeing U.S. Tax Laws
In a contribution to The Wall Street Journal's MarketWatch, Eric Toder explains why corporations expatriate from the United States and argues that they will continue to do so until Congress addresses the fundamental flaws in the corporate income tax. He then provides some possible solutions to...
Review of Conference on What the United States Can Learn From the Experience of Countries with Territorial Tax Systems
On February 28, 2014, the Urban Institute hosted an invitational conference on what policymakers in the United States can learn from the experience of other countries with territorial systems for taxing the income of their multinational corporations. Participants included academic experts,...