ChrisL68
Riley Skinner
- Joined
- Mar 16, 2011
- Messages
- 31,182
- Reaction score
- 3,609
Obama proposed a 28% corporate tax rate (25% for manufacturers) with a 14% repatriation one time tax and a minimum 19% tax on foreign earnings above what couldn't be justified with tangible asset returns and can be offset by 85% of foreign tax credits.
The Senate passed a 20% corporate tax rate (including manufacturers) with a 14.5% repatriation one time tax and a minimum 12.5% tax which can be offset by 80% of foreign tax credits.
The senate includes capital expensing, which Obama's plan wouldn't, but has a 30% interest expense limitation and a high US leveraged multinational interest expense limitation.
The senate also includes a provision that prevents a foreign owned company from loading up a US subsidiary with deductible payments to its parent to avoid paying US taxes. That sub would now have to pay at least 10% of its income plus its deductible related party payments in tax.
There are some base erosion abuse measures that have been needed.
The Senate passed a 20% corporate tax rate (including manufacturers) with a 14.5% repatriation one time tax and a minimum 12.5% tax which can be offset by 80% of foreign tax credits.
The senate includes capital expensing, which Obama's plan wouldn't, but has a 30% interest expense limitation and a high US leveraged multinational interest expense limitation.
The senate also includes a provision that prevents a foreign owned company from loading up a US subsidiary with deductible payments to its parent to avoid paying US taxes. That sub would now have to pay at least 10% of its income plus its deductible related party payments in tax.
There are some base erosion abuse measures that have been needed.