June 22 2021

Congressional Research Service Explains US International Corporate Tax Issues

Source: IBFD Tax Research Platform News

The Congressional Research Service (CRS) of the US Library of Congress has outlined issues and proposals related to the US international corporate tax system in a recently released report. The CRS report is entitled "Issues in International Corporate Taxation: The 2017 Revision (P.L. 115-97)" (R45186-Version 16, 17 June 2021).

The CRS report explains:

  • prior international tax rules and the revisions made in the Tax Cuts and Jobs Act of 2017 (TCJA);
  • the four major issues of concern under prior law:
    • allocation of investment between the United States and other countries;
    • artificial profit shifting out of the United States;
    • repatriation of income earned by foreign subsidiaries; and
    • inversions (US firms shifting their headquarters to other countries for tax reasons);
  • how the TCJA addresses those four concerns or raises new ones;
  • issues associated with international agreements (including tax treaties, the WTO and OECD minimum standards);
  • problems and issues (such as legal challenges, uncertainty and new regulations) within the new international tax regime; and
  • options that have been suggested in President Biden's legislative proposals and bills introduced in Congress.

Note: The CRS is an agency within the US Library of Congress and serves the US Congress throughout the legislative process by providing legislative research and analysis for an informed national legislature.