What Are the Goals of Retaliatory Tax Policies?
The US Ways and Means Committee’s “Big Beautiful Bill” includes a retaliatory provision called Section 899, along with an expansion of the base erosion and anti-abuse tax (BEAT).
7 min read
Expert
Alan Cole
Senior Economist
Alan Cole is a Senior Economist with Tax Foundation’s Center for Federal Tax Policy. His areas of focus include business taxes, cross-border taxes, and macroeconomics.
In addition to work at Tax Foundation, Alan Cole has served on the Joint Economic Committee and with The Conference Board, and published on a variety of economic topics. Alan has a bachelor’s degree in economics from Yale University and an MBA majoring in finance and public policy from the Wharton School. Alan lives in Washington, D.C., with his wife and daughter.
Latest Work
Trump’s Reciprocal Tariff Calculations Are Nonsense, Will Punish Mutually Beneficial Trade
Despite characterizing the tariffs as “reciprocal,” the White House didn’t actually measure tariffs, currency manipulation, or trade barrier policies employed by other countries. Instead, it drew its estimates from something else entirely: bilateral trade deficits in goods.
7 min read
How Will President Trump’s Tariffs Affect the Value of the Dollar?
President Trump has announced that new tariffs will go into effect on April 2, following several weeks of threats. These new tariffs are likely to be broader in scope than the limited ones implemented thus far. So who is likely to pay for them?
7 min read
Considering Potential International Corporate Tax Reforms in the US
Tax legislation in 2025 may have good reason to address international corporate income taxes, because of scheduled changes slated to go into effect or because of international developments like the Pillar Two agreement.
63 min read
Five Things to Know About Trump’s Global Minimum Tax Order
This week, the incoming Trump administration issued a day-one executive order on the global minimum tax agreement known as Pillar Two, which seeks to ensure multinational corporations pay at least 15 percent in income tax.
6 min read
Americans Abroad Need Compliance Cost Relief
Trump’s proposal would bring the US more in line with most other developed economies, which tax only those who live and work within their borders.
4 min read
Pillar Two: Electric Boogaloo
The global tax deal and Pillar Two are shaking up the tax landscape worldwide, introducing a web of complexity and confusion.
Puerto Rican Competitiveness and Pillar Two
Puerto Rico, a US territory with a limited ability to set its own tax policies, will be the first part of the US to be substantially affected by Pillar Two, the global tax agreement that seeks to establish a 15 percent minimum tax rate on corporate income.
17 min read
Supreme Court Rules against Moores 7-2, Leaves Most Questions Undecided
The government won in Moore. However, given the narrow opinion of the court and the reasoning in the Barrett concurrence and the Thomas dissent, it seems likely that future rulings under other facts and circumstances could favor taxpayers instead.
7 min read
Why We’re Closely Watching Moore v. U.S.
The Moore case could have important impacts on tax policy.
5 min read
How to Improve the Base Erosion and Anti-Abuse Tax
BEAT is intended to address a legitimate problem, and there are virtues to BEAT’s overall strategic approach; however, its execution leaves room for improvement.
7 min read
The Impact of BEPS 1.0
The global landscape of international corporate taxation is undergoing significant transformations as jurisdictions grapple with the difficulty of defining and apportioning corporate income for the purposes of tax.
22 min read
The Fatal Flaw of Pillar Two
Pillar Two, the international global minimum tax agreement, has a considerable chance of failing and may ultimately allow the same problems it was designed to address.
6 min read
The Impact of GILTI, FDII, and BEAT
The Tax Cuts and Jobs Act of 2017 (TCJA) reformed the U.S. system for taxing international corporate income. Understanding the impact of TCJA’s international provisions thus far can help lawmakers consider how to approach international tax policy in the coming years.
30 min read
Why Moore v. U.S. Won’t Get Us a Consumption Tax Base
At first glance, a ruling for the plaintiffs in Moore might seem to solve some of the timing problems with the U.S. tax system. Unfortunately, upon greater inspection, such a ruling might create new timing problems. And the more rigid the ruling, the harder it would be to fix the timing problems it would create.
5 min read
Anti-Avoidance Policies in a Pillar Two World
The global minimum tax agreement known as Pillar Two is intended to curb profit shifting. However, OECD countries already have a variety of mechanisms in place that seek to prevent base erosion and profit shifting by multinational corporations.
40 min read
How the U.S. Can Piece Together a Solution for Pillar Two
Congress should recognize that Pillar Two has significant U.S.-specific downsides, but also that it cannot unilaterally stop Pillar Two from taking effect. Instead, it should carefully consider a policy response for the next Congress, when a variety of forces are likely to compel it to act.
7 min read
How the Moore Supreme Court Case Could Reshape Taxation of Unrealized Income
A major case pending before the U.S. Supreme Court (Moore v. United States) is calling into question provisions on large portions of the U.S. tax base which could quickly become legally uncertain, putting significant revenue at stake.
7 min read
Risks to the U.S. Tax Base from Pillar Two
A growing international tax agreement known as Pillar Two presents two new threats to the U.S. tax base: potential lost revenue and limitations on Congress’s ability to set its own tax policy.
39 min read
Interesting Interest Rates
Interest rates and tax policy, two vital components of our economic landscape, often interact in fascinating ways. They influence the behavior of individuals, businesses, and governments. But how exactly?