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U.S. Cross-border Tax Reform and the Cautionary Tale of GILTI
Daniel Bunn
Key Findings
The U.S. joined many other developed nations in adopting territorial provisions and anti-base erosion rules as part of the 2017 tax reform.
One major piece of that reform, that is not typical in other territorial systems, is a new definition of currently taxable foreign earnings, Global Intangible Low Tax Income (GILTI), which is taxed at an effective rate of 13.125 percent, with the rate set to increase after 2025 to 16.4 percent.
Recent research has shown that foreign earnings of U.S. companies remain taxed at similar rates even after the 2017 reforms, implying that while the structure of U.S. taxes on foreign earnings changed, the overall burden did not.
At a Meeting of the Faculty of Arts and Sciences on February 2, 2021, the following tribute to the life and service of the late Martin Stuart Feldstein, was placed upon the permanent records of the Faculty.
Martin Feldstein, who taught at Harvard for more than half a century, was one of the most influential economists of our era. His scientific contributions, spanning an astonishing number of applied fields, pointed the way to new areas of inquiry and new ways of carrying out research that countless economists followed. He advised numerous U.S. presidents and other public officials, serving as chairman of the Council of Economic Advisers in the Reagan administration, on the Foreign Intelligence Advisory Board under the second President Bush, and on President Obama’s Economic Recovery Advisory Board. His economic ideas, in key ways a departure from what had prevailed since World War II, came to represent mainstream American economic policy thinking. And through his leadership of th