Because it’s so confusing of course!
The International tax provisions on the table for revision relate to GILTI, FDII, QBAI, earnings stripping, intangible assets, Subpart F, Transfer Pricing, FDII and BEAT. Who even knows what these mean???
Most members of Congress don’t, they have no real understanding of these provisions and how they impact US taxpayers. And so they will be easily swayed to make changes to these provisions in the mad rush to balance the budget and raise the necessary tax revenue to do so.
This is especially true as some Democratic members of Congress have made it clear that they will not support raising the corporate tax rate to 28%. Thus compelling the Biden administration to look for other sources to raise the necessary revenue.
So what can you expect if the proposed legislation becomes law?
- Higher taxes on GILTI income
- Good-bye FDII deduction
- More scrutiny on base erosion payments
- BEAT fading into the sunset to be replaced by SHIELD (Stopping Harmful Inversions and Ending Low-Tax Developments)
- Changes to the Anti-Inversion rules
- Global Minimum Tax
International Tax Services