The Biden administration has released the Green Book with a package of tax proposals for its FY 2023 Budget. These include:
replacing the base erosion and anti-avoidance tax (BEAT) with the OECD pillar two’s undertaxed payment rule (UTPR) for tax years beginning in 2024. A US domestic minimum top-up tax (at a 15% rate) would be part of the rules to protect US revenues from the imposition of UTPR by other countries. The UTPR would not apply to income subject to the US’s global intangible low-taxed income (GILTI) regime;
raising the corporate tax rate from 21% to 28% effective for tax years beginning from 1 January 2023, with transitional rules; and
a new minimum tax on wealthy individuals, called the ‘billionaire’s tax’ that would impose a 20% minimum tax on total income for taxpayers with wealth of greater than $100m.
The Budget assumes that changes to the GILTI regime set out in the Build Back Better Act will be enacted, giving an effective GILTI rate of 20% which is applied on jurisdiction by jurisdiction basis.
The Biden administration had previously attempted to replace the BEAT rules with a SHIELD (stopping harmful inversions and ending low-tax developments) proposal.
The Biden administration has released the Green Book with a package of tax proposals for its FY 2023 Budget. These include:
replacing the base erosion and anti-avoidance tax (BEAT) with the OECD pillar two’s undertaxed payment rule (UTPR) for tax years beginning in 2024. A US domestic minimum top-up tax (at a 15% rate) would be part of the rules to protect US revenues from the imposition of UTPR by other countries. The UTPR would not apply to income subject to the US’s global intangible low-taxed income (GILTI) regime;
raising the corporate tax rate from 21% to 28% effective for tax years beginning from 1 January 2023, with transitional rules; and
a new minimum tax on wealthy individuals, called the ‘billionaire’s tax’ that would impose a 20% minimum tax on total income for taxpayers with wealth of greater than $100m.
The Budget assumes that changes to the GILTI regime set out in the Build Back Better Act will be enacted, giving an effective GILTI rate of 20% which is applied on jurisdiction by jurisdiction basis.
The Biden administration had previously attempted to replace the BEAT rules with a SHIELD (stopping harmful inversions and ending low-tax developments) proposal.
