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Tax Policy

Update on the Revenue Effects of GILTI and FDII, 2026 Rate Changes, and Proposed Policy Reforms

Update on the Revenue Effects of GILTI and FDII, 2026 Rate Changes, and Proposed Policy Reforms

We analyze new data from the US Treasury to examine historical revenue effects of TCJA’s international corporate tax provisions. We also provide updated conventional estimates to assess the revenue impact of scheduled 2026 rate increases on foreign income of US corporations and assess several proposals that aim to further increase tax revenue.

Taxing Foreign Affiliates of U.S.-Domiciled Firms

Taxing Foreign Affiliates of U.S.-Domiciled Firms

We explain how the PWBM uses its dynamic Overlapping Generation (OLG) model to analyze tax policies affecting foreign-earned income by affiliates of U.S.-domiciled firms. We evaluate two illustrative policy changes: we show how firms’ tax liabilities and the allocation of capital between domestic and international production are affected by an increase in foreign tax rates and a decrease in U.S. tax exemptions on foreign-derived income.

The End of the Double Irish: Implications for US Multinationals and Global Tax Competition

The End of the Double Irish: Implications for US Multinationals and Global Tax Competition

After Ireland ended the Double Irish tax planning strategy in 2020, US firms with historical links to Ireland have shifted their intellectual property (IP) away from traditional tax havens to Ireland and the US to take advantage of tax incentives offered by both countries. This has coincided with a significant increase in Irish corporate tax revenue, particularly for less capital-intensive firms. Repatriation of foreign earnings to the United States has also increased, but fiscal benefits to the US have been offset by tax incentives passed under TCJA.

Computer Sector Investment Tax Incentives: Economic and Budgetary Effects

Computer Sector Investment Tax Incentives: Economic and Budgetary Effects

We examine two major investment tax incentives for the computer sector. The impact on computer-sector investment as well as economy-wide investment is very small, even when the computer sector is modeled as a production complement.

The 2024 Harris Campaign Policy Proposals: Budgetary, Economic and Distributional Effects

The 2024 Harris Campaign Policy Proposals: Budgetary, Economic and Distributional Effects

We estimate that the Harris Campaign tax and spending proposals would increase primary deficits by $1.2 trillion over the next 10 years on a conventional basis and by $2.0 trillion on a dynamic basis that includes a reduction in economic activity. Lower and middle-income households generally benefit from increased transfers and credits on a conventional basis, while higher-income households are worse off.

The 2024 Trump Campaign Policy Proposals: Budgetary, Economic and Distributional Effects

The 2024 Trump Campaign Policy Proposals: Budgetary, Economic and Distributional Effects

We estimate that the Trump Campaign tax and spending proposals would increase primary deficits by $5.8 trillion over the next 10 years on a conventional basis and by $4.1 trillion on a dynamic basis that includes economic feedback effects. Households across all income groups benefit on a conventional basis.

The Budgetary and Economic Effects of permanently extending the 2017 Tax Cuts and Jobs Acts’ expiring provisions

The Budgetary and Economic Effects of permanently extending the 2017 Tax Cuts and Jobs Acts’ expiring provisions

Several provisions in the Tax Cuts and Jobs Act (TCJA) are scheduled to expire (“sunset”) by the end of 2025. We estimate that permanently extending the TCJA would increase primary deficits by $4.0 trillion over the next decade on a conventional basis and by $3.83 trillion including economic feedback effects. By 2054, debt would increase by 16 percent. The policy would modestly increase GDP (by 0.2 percent) relative to current law.

President Biden’s FY2025 Budget Proposal: Budgetary and Economic Effects

President Biden’s FY2025 Budget Proposal: Budgetary and Economic Effects

PWBM estimates that President Biden’s FY2025 budget proposal would reduce primary deficits by $1.7 trillion over the 2025-2034 budget window. Accounting for economic feedback effects, GDP falls by 0.8 percent relative to current law in 2034. By 2054, debt falls by 5.4 percent and GDP declines by 1.3 percent relative to current law.

Policy Options for Reducing the Federal Debt: Spring, 2024

Policy Options for Reducing the Federal Debt: Spring, 2024

We analyze the budgetary and economic effects of three very different illustrative policy bundles that reduce federal budget deficits over time without shrinking the economy relative to current law with rising debt. The results also demonstrate how federal debt falls short of measuring the true fiscal burden being shifted to future generations.

Recent Trends in US Multinational Activity

Recent Trends in US Multinational Activity

We examine recent trends in the activities of US multinationals and their foreign affiliates using data from the Bureau of Economic Analysis’s annual survey of US direct investment abroad. Since the passage of the Tax Cuts and Jobs Act (TCJA), multinational activity has become more domestically concentrated, continuing a trend that started before the legislation. This has coincided with a decline in the US effective corporate tax rate and relatively stable foreign effective tax rates.

Lifting the SALT Cap: Estimated Budgetary Effects, 2024 and Beyond

Lifting the SALT Cap: Estimated Budgetary Effects, 2024 and Beyond

The House of Representative is considering legislation that would retroactively double the cap on deductions for state and local taxes (SALT) for married filers for just 2023, which PWBM previously estimated would cost $12 billion. This brief examines the cost of cap increases if enacted for tax years 2024 and beyond. Depending on the policy design—including size of the cap, AGI limit, and filing status requirements—the additional cost varies from $22 billion to $197 billion over 10 years. However, if other expiring provisions of the Tax Cuts and Jobs Act (TCJA) of 2017 were also extended permanently, the SALT-related costs alone increase to between $107 billion to $1,116 billion, depending on policy design.

Budgetary Cost of the Wyden-Smith (H.R. 7024) Tax Proposal: Conventional Estimates

Budgetary Cost of the Wyden-Smith (H.R. 7024) Tax Proposal: Conventional Estimates

PWBM estimates that the Wyden-Smith tax proposal (H.R. 7024) would reduce revenues by $3 billion over the next decade on a conventional basis.

Why are Changes to IRS Funding Always Scored as Increasing the Deficit?

Why are Changes to IRS Funding Always Scored as Increasing the Deficit?

The House of Representatives is considering legislation that would rescind $14.3 billion of IRS funding as a budgetary offset for a package that provides aid to Israel. CBO estimates that the decrease in IRS funding alone would reduce revenue by $26.8 billion over 10 years, increasing the deficit by $12.5 billion. Due to scoring conventions, CBO’s projected deficit increase could not be reversed for any future legislation that adds the $14.3 billion in funding back to the IRS.

Pillar Two and the U.S.: A Policy Explainer for Navigating the Global Minimum Tax

The OECD expects countries to implement components of Pillar Two, its framework for a global minimum tax, starting in 2024. The US is likely to cede tax rights to foreign jurisdictions if it does not enact new tax law. Pillar Two will likely reshape the nature of tax competition between countries, incentivizing greater use of subsidies and refundable tax credits to counteract higher statutory rates.

W2023-1 Pillar Two and the U.S.: A Policy Explainer for Navigating the Global Minimum Tax

Did Tax Cuts and Jobs Act of 2017 Increase Revenue on US Corporations’ Foreign Income?

Did Tax Cuts and Jobs Act of 2017 Increase Revenue on US Corporations’ Foreign Income?

Despite a complete overhaul of the US system of international corporate taxation in the Tax Cuts and Jobs Act of 2017, taxes on US corporations’ foreign income are about the same after the law’s enactment as before.

A Wide Range of Policy Bundles Can Stabilize Federal Debt while Growing the Economy

A Wide Range of Policy Bundles Can Stabilize Federal Debt while Growing the Economy

Debt ceiling debates would become less frequent if Congress adopted fiscal measures that limited the growth of federal government debt relative to the size of the economy. Without changes in fiscal policy, we project that the debt-to-GDP ratio will grow from 100 percent in 2024 to 190 percent in 2050. Contrary to conventional thinking, there exists a wide range of policy options that can reduce the growth of debt while growing the economy.

The Build It in America Act: Budgetary and Macroeconomic Effects of Title I

The Build It in America Act: Budgetary and Macroeconomic Effects of Title I

PWBM estimates that Title I of the Build It in America Act would add $76 billion to the budget deficit over the next decade and reduce deficits by $18 billion during the subsequent second decade. It would temporarily boost business investment and GDP during the next two years while lowering GDP in subsequent years. If lawmakers made the extensions permanent, the budgetary cost would rise to $1.25 trillion over the next two decades and GDP would largely remain unchanged, as the tax incentive effects and debt effects mostly offset.

The Tax Cuts for Working Families Act: Estimated Budgetary and Distributional Effects

The Tax Cuts for Working Families Act: Estimated Budgetary and Distributional Effects

PWBM estimates the Tax Cuts for Working Families Act would reduce federal revenues by $96 billion over a decade, cutting taxes for a majority of households in 2024. Households in the bottom quintile households, and those in the top 1 percent, generally would not benefit. As an illustration, we also consider making the provisions permanent, which raises the estimated ten-year budget cost to be between $419 billion and $527 billion.

The Long-Term Budget Effects of Permanently Extending the 2017 Tax Cuts and Jobs Act’s Expiring Provisions

The Long-Term Budget Effects of Permanently Extending the 2017 Tax Cuts and Jobs Act’s Expiring Provisions

Several revenue and spending provisions in The Tax Cuts and Jobs Act (TCJA) are scheduled to expire (“sunset”) by the end of 2025. We estimate that “extenders” (“no sunset”) would increase the federal debt held by the public from 226.0 percent of GDP to 261.1 percent of GDP by 2050.