Skip to content Skip to footer
Search

Loading Results

Cross-border Tax Talks

June 08, 2021

Explaining the explanation: Biden’s Greenbook

Doug McHoney (PwC's US International Tax Services (ITS) Leader) holds the second post-vaccine session live at the Westminster Studios with Pat Brown (PwC WNTS Policy Co-leader) to discuss President Biden’s FY 22 Budget and the much anticipated and related explanations of such proposals, also known as the Treasury Green Book. Doug and Pat cover, among other proposals: increasing the US corporate income tax rate from 21% to 28%; increasing the global intangible low-taxed income (GILTI) tax rate to 21%; removing the qualified business asset investment (QBAI) provision; repealing the deduction for foreign derived intangible income (FDII); replacing the Base Erosion and Anti-Abuse Tax (BEAT) with a Stopping Harmful Inversions and Ending Low-tax Developments (SHIELD) provision; restricting deductions of excessive interest for disproportionate borrowing in the US; the status and likelihood of the OECD’s Pillars One and Two; and what companies should consider as potential tax legislation becomes more likely.

Timestamps:

  • 2:30 - What is the ‘Green Book’?
  • 5:30 - How does the Green Book become law?
  • 7:30 - Where is the Administration heading with the corporate tax rate?
  • 11:30 - Why is it important for US-headquartered companies to be competitive in foreign markets outside the United States?
  • 17:00 - What is the reasoning behind repealing FDII?
  • 23:00 - What are some of the sweeping changes made to the GILTI regime?
  • 29:30 - How do these proposals affect what some consider to be a territorial tax system under TCJA?
  • 31:30 - What are the proposed changes to Section 265?
  • 35:30 - What is the new SHIELD regime that is being proposed to replace the BEAT?
  • 40:30 - How similar are this Green Book’s interest deductions proposals to those released during the Obama Administration?
  • 43:30 - What is the Administration’s view on limiting inversions?
  • 45:30 - What is the 15% minimum tax on book income?
  • 47:30 - How does the new proposal limiting foreign tax credits on hybrid entities work?
  • 49:30 - What are the new changes to the  taxation of foreign fossil fuel income?
  • 51:00 - How does the prospects of an OECD global minimum tax interact with the US tax proposals?

 

View full podcast series




Contact us

Doug McHoney

International Tax Services Global Leader, PwC US

Geoff Jacobi

ITS, Knowledge Management Managing Director, PwC US

Follow us