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The Tax Policy Center's

Briefing Book

A citizen’s guide to the fascinating (though often complex) elements of the US tax system.

Tax Policy Center Briefing Book

Key Elements of the U.S. Tax System

  • Briefing Book
  • Taxes and Multinational Corporations
  • How does the tax system affect US competitiveness?
  • Chapters
    • Introduction
      • Introduction
        • Introduction
    • Some Background
      • Federal Budget
        • What are the sources of revenue for the federal government?
        • How does the federal government spend its money?
        • What is the breakdown of revenues among federal, state, and local governments?
        • How do US taxes compare internationally?
      • Federal Budget Process
        • How does the federal budget process work?
        • What is the history of the federal budget process?
        • What is the schedule for the federal budget process?
        • What is reconciliation?
        • How is a budget resolution enforced?
        • What is PAYGO?
        • What are rescissions?
      • Federal Budget Outlook
        • How accurate are long-run budget projections?
        • What have budget trends been over the short and long term?
        • How much spending is uncontrollable?
        • What are tax extenders?
        • What options would increase federal revenues?
        • What does it mean for a government program to be off-budget?
        • How did the TCJA affect the federal budget outlook?
      • Taxes and the Economy
        • How do taxes affect the economy in the short run?
        • How do taxes affect the economy in the long run?
        • What are dynamic scoring and dynamic analysis?
        • Do tax cuts pay for themselves?
        • On what do economists agree and disagree about the effects of taxes on economic growth?
        • What are the economic effects of the Tax Cuts and Jobs Act?
      • Economic Stimulus
        • What is the role of monetary policy in alleviating economic downturns?
        • What are automatic stabilizers and how do they work?
        • What characteristics make fiscal stimulus most effective?
      • Distribution of Tax Burdens
        • How are federal taxes distributed?
        • Are federal taxes progressive?
        • How should progressivity be measured?
        • What is the difference between marginal and average tax rates?
        • What criticisms are levied against standard distributional analysis?
        • How should distributional tables be interpreted?
        • Who bears the burden of the corporate income tax?
        • Who bears the burden of federal excise taxes?
        • How do financing methods affect the distributional analyses of tax cuts?
        • How do taxes affect income inequality?
      • Tax Expenditures
        • What are tax expenditures and how are they structured?
        • What is the tax expenditure budget?
        • Why are tax expenditures controversial?
        • What are the largest tax expenditures?
        • How did the TCJA affect tax expenditures?
      • Tax Gap and Tax Shelters
        • What is the tax gap?
        • What does the IRS do and how can it be improved?
        • What is a tax shelter?
      • Recent History of the Tax Code
        • What did the 2008–10 tax stimulus acts do?
        • What did the American Taxpayer Relief Act of 2012 do?
        • How did the Tax Cuts and Jobs Act change personal taxes?
        • How did the Tax Cuts and Jobs Act change business taxes?
    • Key Elements of the U.S. Tax System
      • Individual Income Tax
        • What is the standard deduction?
        • What are itemized deductions and who claims them?
        • How did the TCJA change the standard deduction and itemized deductions?
        • What are personal exemptions?
        • How do federal income tax rates work?
        • What are tax credits and how do they differ from tax deductions?
        • How do phaseouts of tax provisions affect taxpayers?
      • Capital Gains and Dividends
        • How are capital gains taxed?
        • What is the effect of a lower tax rate for capital gains?
        • What is carried interest, and how is it taxed?
        • How might the taxation of capital gains be improved?
      • AMT
        • What is the AMT?
        • Who pays the AMT?
        • How much revenue does the AMT raise?
        • How did the TCJA change the AMT?
      • Taxes and the Family
        • What is the child tax credit?
        • What is the adoption tax credit?
        • What is the earned income tax credit?
        • Do all people eligible for the EITC participate?
        • How does the tax system subsidize child care expenses?
        • What are marriage penalties and bonuses?
        • How did the TCJA change taxes of families with children?
      • Taxes and the Poor
        • How does the federal tax system affect low-income households?
        • What is the difference between refundable and nonrefundable credits?
        • Can poor families benefit from the child tax credit?
        • Why do low-income families use tax preparers?
        • How does the earned income tax credit affect poor families?
        • What are error rates for refundable credits and what causes them?
        • How do IRS audits affect low-income families?
      • Taxes and Retirement Saving
        • What kinds of tax-favored retirement arrangements are there?
        • How large are the tax expenditures for retirement saving?
        • What are defined benefit retirement plans?
        • What are defined contribution retirement plans?
        • What types of nonemployer-sponsored retirement savings accounts are available?
        • What are Roth individual retirement accounts?
        • Who uses individual retirement accounts?
        • How does the availability of tax-favored retirement saving affect national saving?
        • What’s the difference between front-loaded and back-loaded retirement accounts?
        • What is an automatic 401(k)?
        • How might low- and middle-income households be encouraged to save?
      • Taxes and Charitable Giving
        • What is the tax treatment of charitable contributions?
        • What entities are tax-exempt?
        • Who benefits from the deduction for charitable contributions?
        • How would various proposals affect incentives for charitable giving?
        • How large are individual income tax incentives for charitable giving?
        • How did the TCJA affect incentives for charitable giving?
      • Taxes and Health Care
        • How much does the federal government spend on health care?
        • Who has health insurance coverage?
        • Which tax provisions subsidize the cost of health care?
        • How does the tax exclusion for employer-sponsored health insurance work?
        • What are premium tax credits?
        • What tax changes did the Affordable Care Act make?
        • How do health savings accounts work?
        • How do flexible spending accounts for health care expenses work?
        • What are health reimbursement arrangements and how do they work?
        • How might the tax exclusion for employer-sponsored health insurance (ESI) be reformed?
      • Taxes and Homeownership
        • What are the tax benefits of homeownership?
        • Do existing tax incentives increase homeownership?
      • Taxes and Education
        • What tax incentives exist for higher education?
        • What tax incentives exist to help families pay for college?
        • What tax incentives exist to help families save for education expenses?
        • What is the tax treatment of college and university endowments?
      • Tax Complexity
        • Why are taxes so complicated?
        • What are the benefits of simpler taxes?
        • What policy reforms could simplify the tax code?
      • Wealth Transfer Taxes
        • How do the estate, gift, and generation-skipping transfer taxes work?
        • Who pays the estate tax?
        • How many people pay the estate tax?
        • What is the difference between carryover basis and a step-up in basis?
        • How could we reform the estate tax?
        • What are the options for taxing wealth transfers?
        • What is an inheritance tax?
      • Payroll Taxes
        • What are the major federal payroll taxes, and how much money do they raise?
        • What is the unemployment insurance trust fund, and how is it financed?
        • What are the Social Security trust funds, and how are they financed?
        • Are the Social Security trust funds real?
        • What is the Medicare trust fund, and how is it financed?
      • Excise Taxes
        • What are the major federal excise taxes, and how much money do they raise?
        • What is the Highway Trust Fund, and how is it financed?
      • Energy and Environmental Taxes
        • What tax incentives encourage energy production from fossil fuels?
        • What tax incentives encourage alternatives to fossil fuels?
        • What is a carbon tax?
      • Business Taxes
        • How does the corporate income tax work?
        • What are pass-through businesses?
        • How are pass-through businesses taxed?
        • Is corporate income double-taxed?
      • Tax Incentives for Economic Development
        • What is the new markets tax credit, and how does it work?
        • What is the Low-Income Housing Tax Credit and how does it work?
        • What are Opportunity Zones and how do they work?
      • Taxes and Multinational Corporations
        • How does the current system of international taxation work?
        • How do US corporate income tax rates and revenues compare with other countries’?
        • What are the consequences of the new US international tax system?
        • How does the tax system affect US competitiveness?
        • How would formulary apportionment work?
        • What are inversions, and how will TCJA affect them?
        • What is a territorial tax and does the United States have one now?
        • What is the TCJA repatriation tax and how does it work?
        • What is the TCJA base erosion and anti-abuse tax and how does it work?
        • What is global intangible low-taxed income and how is it taxed under the TCJA?
        • What is foreign-derived intangible income and how is it taxed under the TCJA?
    • How Could We Improve the Federal Tax System?
      • Comprehensive Tax Reform
        • What is comprehensive tax reform?
        • What are the major options for comprehensive tax reform?
      • Broad-Based Income Tax
        • What is a broad-based income tax?
        • What would and would not be taxed under a broad-based income tax?
        • What would the tax rate be under a broad-based income tax?
      • National Retail Sales Tax
        • What is a national retail sales tax?
        • What would and would not be taxed under a national retail sales tax?
        • What would the tax rate be under a national retail sales tax?
        • What is the difference between a tax-exclusive and tax-inclusive sales tax rate?
        • Who bears the burden of a national retail sales tax?
        • Would tax evasion and avoidance be a significant problem for a national retail sales tax?
        • What would be the effect of a national retail sales tax on economic growth?
        • What transition rules would be needed for a national retail sales tax?
        • Would a national retail sales tax simplify the tax code?
        • What can state and local sales taxes tell us about a national retail sales tax?
        • What is the experience of other countries with national retail sales taxes?
        • What did the President’s Advisory Panel on Federal Tax Reform say about the national retail sales tax?
      • Value Added Tax (VAT)
        • What is a VAT?
        • How would a VAT be collected?
        • What would and would not be taxed under a VAT?
        • What would the tax rate be under a VAT?
        • What is the difference between zero rating and exempting a good in the VAT?
        • Who would bear the burden of a VAT?
        • Is the VAT a money machine?
        • How would small businesses be treated under a VAT?
        • What is the Canadian experience with a VAT?
        • Why is the VAT administratively superior to a retail sales tax?
        • What is the history of the VAT?
        • How are different consumption taxes related?
      • Other Comprehensive Tax Reforms
        • What is the flat tax?
        • What is the X-tax?
      • Recent Comprehensive Tax Reform Proposals
        • Simple, Fair, and Pro-Growth: Proposals to Fix America’s Tax System, Report of the President’s Advisory Panel on Federal Tax Reform, November 2005
        • The Moment of Truth: Report of the National Commission on Fiscal Responsibility and Reform, December 2010
        • Debt Reduction Task Force, “Restoring America’s Future,” Bipartisan Policy Center, November 2010
        • The Tax Reform Act of 2014: Fixing Our Broken Tax Code So That It Works for American Families and Job Creators, House Ways and Means Committee
        • The Graetz Competitive Tax Plan, Updated for 2015
      • Return-Free Tax Filing
        • What is return-free filing and how would it work?
        • What are the benefits of return-free filing?
        • What are the drawbacks of return-free filing?
        • How would the tax system need to change with return-free filing?
        • Who would qualify for return-free filing?
        • Would return-free filing raise taxes?
        • What was the experience with return-free filing in California?
        • What other countries use return-free filing?
    • The State of State (and Local) Tax Policy
      • State and Local Revenues
        • What are the sources of revenue for state governments?
        • What are the sources of revenue for local governments?
      • Specific State and Local Taxes
        • How do state and local individual income taxes work?
        • How do state and local sales taxes work?
        • How do state and local property taxes work?
        • How do state and local corporate income taxes work?
        • How do state estate and inheritance taxes work?
        • How do state earned income tax credits work?
        • How do state and local severance taxes work?
        • How do state and local soda taxes work?
        • How do marijuana taxes work?
      • Fiscal Federalism and Fiscal Institutions
        • How does the deduction for state and local taxes work?
        • What are municipal bonds and how are they used?
        • What types of federal grants are made to state and local governments and how do they work?
        • What are state rainy day funds, and how do they work?
        • What are tax and expenditure limits?
        • What are state balanced budget requirements and how do they work?
    • Glossary
      • Glossary
        • Glossary

How does the tax system affect US competitiveness?

Taxes and Multinational Corporations

<4/11>
Business Taxes
Q.

How does the tax system affect US competitiveness?

A.

The international tax policies that best encourage firms to invest in the United States are not necessarily the policies that best help US multinational companies compete with foreign-based multinationals. Policymakers face a trade-off among goals.

WHAT IS COMPETITIVENESS?

Many—really all—politicians favor “international competitiveness,” but the term means different things to different people. To some, it means domestic firms or industries can compete with their foreign counterparts in a global marketplace. For them, this translates into support for “mercantilist” policies that seek to increase exports, reduce imports, or promote more US activity in certain sectors, such as manufacturing.

An alternative form of mercantilism seeks to promote the growth of a country’s resident multinational corporations without regard to whether they produce at home or overseas. Concerns about the competitiveness of US multinationals often follow from an assumption that these firms generate spillover benefits for the economy in which they are headquartered. For example, the knowledge created by research and development (R&D) (typically conducted at headquarters) often gets diffused to other domestic producers, boosting productivity more broadly.

By contrast, many economists view free trade and capital movements as mutually beneficial because they raise living standards in all countries. These economists define “competitive” policies as those that increase Americans’ standard of living over the long run, without regard to their effects on the balance of trade, the net direction of international capital flows, or success in expanding specific activities, such as manufacturing or R&D.

Global international tax practices seek to promote free capital movements by preventing double taxation of international capital flows. These same practices assign the capital-importing countries rights to tax profits (i.e., the country where production facilities are located).

The capital-exporting country has two ways to avoid double taxation. The first method is simply to exempt taxation of the foreign-source income of its resident companies. The second method is to tax the worldwide income of its resident companies but to allow them to claim credits for foreign income taxes so that their income is taxed at the home-country rate rather than the rate in the country where the income is earned. These two approaches have different implications for a country’s attractiveness either as a location for productive investment or as a place for multinational corporations to establish residence.

Although the promise of beneficial spillovers provides an argument for using the tax code to promote R&D and other headquarters activities, direct subsidies such as research credits would be a more cost-effective way to encourage research.

HOW CAN TAX POLICIES ATTRACT INVESTMENT?

Following the 2017 Tax Cuts and Jobs Act (TCJA), the US corporate tax system no longer discourages investment in the United States by US- and foreign-based corporations. Now the top corporate tax rate in the United States (including the effect of state-level taxes) is slightly below the average corporate tax rate of our major trading partners. In addition, capital recovery provisions are more generous in the United States than in many other countries, especially through 2022 when companies can immediately deduct 100 percent of costs of machinery and equipment investment in the United States. (This bonus depreciation provision phases out between 2023 and 2027 at 20 percentage points per year.)

Provisions that make it easier in the United States than in most other countries to establish businesses whose owners benefit from limited liability without being subject to corporate-level taxation also encourage domestic investment. For example, many US corporations lease office buildings from real-estate investment trusts, which pay no corporate income tax, instead of owning them and facing US corporate income tax on the profits they generate.

The US tax system after the TCJA continues to encourage US-based multinationals to invest in low-tax foreign countries instead of at home. US multinationals pay no US tax on foreign-source income up to 10 percent of the value of their tangible foreign capital (the value, net of past depreciation, of machinery, equipment, and structures). But most of the overseas tangible capital of US multinationals is in other major economies with corporate tax rates now similar to or slightly higher than the US corporate tax rate. Exemption of these profits, then, provides little additional benefit. On these investments, there would be no US tax liability—even in a worldwide system—because the credit for foreign income taxes would fully offset US corporate income tax liability.

HOW CAN TAX POLICIES ATTRACT CORPORATE HEADQUARTERS?

The US tax system places US multinationals at a competitive disadvantage with foreign-based multinationals that have income from low-tax countries. US companies now face a 10.5 percent minimum tax on global intangible low-taxed income, defined as global profits above 10 percent of tangible capital. In contrast, most countries in the Organisation for Economic Co-operation and Development and all the other countries in the G7 (Canada, France, Germany, Italy, Japan, and the United Kingdom) have exemption systems that allow their resident multinationals to pay only the foreign tax rate on most of their overseas profits.

The US and many other countries have controlled foreign corporation (CFC) rules that tax some forms of US multinationals’ foreign-source income as it accrues in their foreign subsidiaries at the same rate as domestic-source income. The goal of CFC rules is to prevent schemes that shift the reported profits resident multinationals earn at home to their affiliates in low-tax foreign countries. Because CFC rules, however, apply only to domestic-resident multinationals, they do not prevent similar schemes by foreign-resident multinationals to strip profits from their affiliates in high-tax countries.

Several countries have enacted new taxes on foreign-resident multinationals operating in their countries, including the diverted profits tax in the United Kingdom and similar measures in Italy and India and proposed in France. Many countries also have “thin-capitalization” rules that limit interest deductions to prevent outbound income shifting. The base erosion and anti-abuse tax (BEAT) in the TCJA is a new measure that limits income shifting out of the United States by both US and foreign-resident companies. The BEAT imposes an alternative minimum tax on a tax base that disallows the deduction of certain payments to related parties. Some companies may find ways to avoid the BEAT, and the provision may also do unintended collateral harm to other companies, so its effectiveness is debatable. Nonetheless, BEAT is an effort to improve the competitive position of US-based multinationals by limiting the ability of foreign-based companies to strip profits from their US operations.

WOULD A VALUE-ADDED TAX OR DESTINATION-BASED CASH FLOW TAX INCREASE US COMPETITIVENESS?

Some commentators argue that substituting a value-added tax (VAT) for all or part of the corporate income tax would improve the US trade balance. Unlike the corporate income tax and other levies imposed on income earned in the United States, VATs typically exempt exports and tax imports.

But most economists dispute the claim that a VAT would improve the trade balance, arguing that any benefit to net exports from a VAT would be offset by a resulting appreciation of the US dollar relative to other currencies. In fact, some research suggests that countries that rely heavily on VATs for revenue have lower net exports than those that don’t.

Replacing some or all of the corporate income tax with a VAT would, however, affect the trade position of some industries relative to others. Exemptions and lower rates within a VAT affect the relative prices consumers pay for different goods and services but do not distort trade patterns because VAT burdens do not depend on where goods and services are produced. In contrast, preferences within the corporate income tax do affect production location, improving the competitiveness of some US producers while worsening the competitiveness of others, because the tax does affect relative costs of production.

In 2017, House Republicans considered and then abandoned a plan for a destination-based cash flow tax (DBCFT) to replace the corporate income tax. The DBCFT was similar to a VAT in that it would have allowed immediate recovery of capital expenses and would have exempted exports from tax and disallowed a deduction for imports. (It differed from a VAT by allowing companies to deduct wages.) Many commentators expressed concern that the DBCFT would hurt US importers, but prominent economists argued that exchange rates would adjust to neutralize any trade effects of its border-adjustments feature.

Updated May 2020
Further Reading

Arnold, Brian J. 2012. “A Comparative Perspective on the US Controlled Foreign Corporation Rules.” Tax Law Review 65 (3): 474–505.

Auerbach, Alan. 2017. “Demystifying the Destination-Based Cash Flow Tax.” Brookings Papers on Economic Activity. Fall: 409-32.



Clausing, Kimberly A. 2004. “The American Jobs Creation Act of 2004: Creating Jobs for Accountants and Lawyers.” Washington, DC: Urban-Brookings Tax Policy Center.



Desai, Mihir A., and James R. Hines, Jr. 2005. “Value Added Taxes and International Trade: The Evidence.” Harvard Business School working paper. Cambridge, MA: Harvard University.

Desai, Mihir A., C. Fritz Foley, and James R. Hines, Jr. 2009. “Domestic Effects of the Foreign Activities of US Multinationals.” American Economic Journal: Economic Policy 1 (1): 181–203.

Graetz, Michael, and Rachael Doud. 2013. “Technological Innovation, International Competition, and the Challenges of International Income Taxation.” Columbia Law Review 113 (3): 347–446.



Grubert, Harry. 2012. “Foreign Taxes and the Growing Share of US Multinational Company Income Abroad: Profits, Not Sales, Are Being Globalized.” National Tax Journal 65 (2): 247–282.

Kleinbard, Edward D. 2014. “’Competitiveness’ Has Nothing to Do with It.” Tax Notes. September 1.

Slemrod, Joel. 2012. “Competitive Tax Policy.” In Rethinking Competitiveness, edited by Kevin Hassett, 32–65. Washington, DC: American Enterprise Institute for Public Policy Research.

Toder, Eric. 2012. “International Competitiveness: Who Competes against Whom and for What?” Tax Law Review 65 (3): 505–34.



Viard, Alan D. 2004. “Border Adjustments Won’t Stimulate Competitiveness.” Tax Notes. December 4.

———. 2017. “The Economic Effects of Border Adjustments.” Tax Notes. February 20.

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