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Evaluating three minimum taxes on the foreign profits of multinationals by Kyle Pomerleau and Carol Wang

By: Pomerleau, Kyle.
Contributor(s): Wang, Carol.
Material type: ArticleArticlePublisher: 2024Subject(s): IMPUESTO MÍNIMO ALTERNATIVO | EMPRESAS MULTINACIONALES | BENEFICIOS | ESTADOS UNIDOS In: Tax Notes International v. 115, n. 10, September 2 2024, p. 1519-1545Summary: Kyle Pomerleau is a senior fellow at the American Enterprise Institute and Carol Wang is a senior tax counsel at Shartsis Friese LLP. The authors thank Alex Brill, Mindy Herzfeld, Tim Dowd, and Brian Gallagher for feedback on earlier drafts of this article. In this article, Pomerleau and Wang compare and analyze three minimum taxes on the foreign profits of multinational corporations — the global intangible low-taxed income regime, the corporate alternative minimum tax, and pillar 2’s income inclusion rule — evaluating each for impact on economic efficiency, robustness to avoidance, and administrability.
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Kyle Pomerleau is a senior fellow at the American Enterprise Institute and Carol Wang is a senior tax counsel at Shartsis Friese LLP. The authors thank Alex Brill, Mindy Herzfeld, Tim Dowd, and Brian Gallagher for feedback on earlier drafts of this article. In this article, Pomerleau and Wang compare and analyze three minimum taxes on the foreign profits of multinational corporations — the global intangible low-taxed income regime, the corporate alternative minimum tax, and pillar 2’s income inclusion rule — evaluating each for impact on economic efficiency, robustness to avoidance, and administrability.

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