Their plan also supports Biden’s proposal to change the way companies calculate the tax so that they cannot average their GILTI tax bills for all their operations abroad, which tends to reduce their tax bills. But while Biden has proposed that companies be required to calculate the tax for each state, senators are proposing that businesses allow their accounts to be divided between high- and low-tax countries, in a theory that would be easier to administer.
And while Biden proposed to blow up another tax known as the Basic Tax on Erosion and Anti-Abuse and kill the export incentive known as foreign intangible income, the tax authors would keep both but make a number of changes.
“The international tax system needs to focus on rewarding companies that invest in the US and their workers, stop encouraging corporations to change jobs and invest abroad, and ensure that large corporations pay their fair share,”
“These reforms would not only make our international tax system better, they could raise the revenue needed to invest in America.”
The plan comes as Democrats try to raise taxes on large corporations to generate revenue to pay for their infrastructure plan.
Biden began the debate last week with a proposal to raise corporate taxes to offset the cost of his infrastructure plan. Congress will have many changes to the plan, with the House’s lead tax writer suggesting last week that he would propose alternative proposals.
It is also possible that legislators will eventually discard some or all of the tax increases and shift the cost of the spending package to the deficit.
The proposal, released Monday, is remarkable in that it represents a wide range of political spectrum in the Senate Council of Deputies, with Brown at the progressive end and Warner being more moderate.
Their framework still does not have many figures – it does not offer a specific GILTI tax rate, for example. This is because Democrats predict that they will adjust interest rates according to how much money they decide they need to raise.
Like the administration, Senate Democrats work within the international tax system that Republicans are creating as part of their 2017 tax law, although they want to make it much stricter. Democrats’ proposals would bring it closer to a purely “global” tax system in which the United States tries to tax companies no matter where they operate.
Senators want to rewrite BEAT to recover tax breaks for things like solar and affordable housing that companies may already lose from the tax. They also offer a second, higher BEAT tax category, along with their current 10 percent.
“BEAT needs to be reformed to attract more revenue than companies that erode the U.S. tax base and use that revenue to support companies that actually invest in America, ”the plan said.
Lawmakers also want to provide FDII benefits to companies based on how much they spend on things like R&D and training workers in the United States