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re: Explain to me the new tax increases

Posted on 4/1/21 at 12:55 pm to
Posted by Jorts R Us
Member since Aug 2013
14877 posts
Posted on 4/1/21 at 12:55 pm to
quote:

That said, if we aren't worried about moving money out the US why are they proposing measures designed to prevent offshoring of profits?


First, no one is claiming that offshoring of profits isn't a concern.

Second, those measures already exist. The TCJA made repatriation of foreign earnings without US taxation possible which made it all the more necessary to have measures to safeguard against base erosion and profit shifting to low tax jurisdictions. That's why the TCJA introduced GILTI and BEAT. The proposal is to actually beef up GILTI to make it more punitive. I would argue that GILTI is already more punitive than originally intended and impacts industries it was never intended to impact because it interacts poorly with our existing foreign tax credit regime, but that's a separate discussion.

Third, my comment was in respect to your comment on repatriation. As I mentioned above, the rules have changed. US taxation of foreign earnings, the historical deterrent of repatriation, is no longer dependent on bringing the money home. That's not changing under this proposal. Your concern about repatriation is unfounded.

quote:

In, I remind you, an infrastructure bill.


It's included in the infrastructure bill because they are proposing offsetting some of the costs of the bill with the corporate tax hikes. Whether we agree or disagree, this administration has chosen to very publicly link the two.
This post was edited on 4/1/21 at 1:13 pm
Posted by BigJim
Baton Rouge
Member since Jan 2010
14519 posts
Posted on 4/1/21 at 1:39 pm to
quote:

First, no one is claiming that offshoring of profits isn't a concern...That's not changing under this proposal. Your concern about repatriation is unfounded.


My goodness, I already admitted I was being glib.

quote:

It's included in the infrastructure bill because they are proposing offsetting some of the costs of the bill with the corporate tax hikes. Whether we agree or disagree, this administration has chosen to very publicly link the two.


Uhm, it is exactly whether we agree or disagree to use this method. They made not effort to link the two at all. Generally there is sense that yes, people or entities will pay higher taxes but they will reap some benefits. This is historically the case with infrastructure bills and fuel taxes. I don't believe (but I could be wrong) that an infrastructure bill has ever been funded by a corporate tax hike. That should give people pause.

They have completely severed this connection. It is now:
Biden Admin "you want infrastructure and I will tax BIG CORPORATIONS to pay for it!"

Populace: "Yay! Stick it to 'em and get me my roads!"



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