Tuesday, October 26, 2021

New minimum tax proposal for companies' book profits

Reportedly, the Senate Democrats are nearing an agreement on a corporate minimum tax  that would apply in lieu of some things that Senator Sinema opposes, e.g., generally raising the corporate rate.

I am not entirely a fan of minimum taxes, as discussed here. But when political constraints limit what can be enacted, the best shouldn't be the enemy of the sufficiently good. I do think there's a strong case for increasing U.S. corporate tax burdens relative to where the 2017 act left them - as a new article of mine that is coming out in Tax Notes next Monday (November 1) will discuss. So let's consider the merits of doing it in the particular way that the emerging agreement envisions.

The following are the key features that were listed in a fact sheet. The items from the fact sheet are in bold, with comments of mine in regular font.

The Corporate Profits Minimum Tax would:

  •   Apply to roughly 200 companies that report over $1 billion in profits - These probably include many of the leading suspects that are currently earning what look like large rents and paying low taxes. Thus limiting the tax's reach might be viewed as equivalent to imposing graduated corporate rates, which is not generally the best approach. And the exemption amount is surely above the level that one would adopt purely on administrative grounds. Setting it that high is presumably a political  constraint. (I am presuming that it is indeed an exemption amount, to avoid large "cliff" effects when one goes a dollar over the threshold.)

  •   Create a 15% minimum tax on the profits that these giant companies report to shareholders - I suggested here that there may be grounds for assigning some tax liability to book income, not just the income measures devised by legislators. I have since backed off this a bit, since my friends in the accounting profession are so vehemently and almost unanimously opposed to it (although I suspect that there might be a bit of NIMBYism going on there). But in any event this is the direction in which the international tax world is moving, since politically book income nas become the fallback of choice for minimum taxes, faute de mieux. With flawed political institutions setting corporate tax bases, there is certainly a kind of second-best case for doing this. The minimum tax (as opposed to low-rate supplemental tax) design feature is one that I'd probably on balance recommend against, but again that's not to overstate the problems caused by it.

  •   Preserve the value of business credits including R&D, clean energy, and housing tax credits and allow credits for taxes paid to foreign countries - These credits vary in their meritoriousness. I hope the foreign tax credits aren't 100% (i.e., dollar-for-dollar domestic tax reduction for foreign taxes paid, leading to a "marginal reimbursement rate" of 100%, for reasons that I wrote about, for example here. But there are already precedents (such as GILTI) for applying a less than 100% MRR, so I am hopeful that it is also the case here.

  •   Include some flexibilities for companies to carry forward losses and claim a minimum tax credit against regular tax in future years - This is certainly a desirable feature, as it offsets the arbitrariness of annual accounting.

  •   Raise hundreds of billions in revenue over 10 years - Again, while the details will be key, raising that sort of money from these taxpayers is indeed a direction in which I believe we should generally be going.

  • Bottom line, I look forward to seeing further details, but even if some political compromises were necessary, I am hopeful that this will prove to be a meritorious proposal on balance. More to come.


Anonymous said...

Are you interested in any kinds of hacking services?
Feel free to contact TECHNECHHACKS.

For years now we’ve helped so many organizations and companies in hacking services.
TECHNECHHACKS is a team of certified hackers that has their own specialties and they are five star rated hackers.

We give out jobs to hackers (gurus only) to those willing to work, with or without a degree, to speed up the availability of time given to jobs!!

Thus an online binary decoding exam will be set for those who needs employment under the teams establishment.

we deal with the total functioning of sites like,

• SOCIAL MEDIA (Facebook, Twitter, Instagram, Snapchat, google hangout etc.)






Our special agents are five star rated agents that specializes in the following, and will specially be assigned to you for a special job well DONE.








Thus bewere of scammers because most persons are been scammed and they ended up getting all solutions to their cyber bullies and attacks by US.

I am Jason williams one of the leading hack agent.


And our WORK SUCCESS IS 100%!!!

We’re always available for you when you need help.

Contact or write us on:



Jason. W

2021©️All Right Reserved

Nigel Fountain said...

Making an excursion into history, it should be pointed out that the income tax on legal entities appeared relatively recently. It became widespread in connection with the development of a competitive economy based on private property and business forms based on the principle of limited liability, as opposed to the principle of full responsibility, in which any person carrying out commercial activities is responsible for arising debts and for obligations not only capital invested in it, but also with all its property. Back in 2019, they wrote about optimization possibilities in star gambling. Corporate tax is levied on the net profit of companies. However, in most countries the rate is not the only definite one; there are reduced, minimum and maximum tax rates.

Unknown said...

Digital Marketing Institute in KPHB, we address all major and minor aspects required for any student’s advancement in digital marketing. Clutch USA named our Digital Marketing Institute the best SEO firm.

The future of digital marketing is promising and full of possibilities.
As a result, skilled digital marketers who can keep up with the rising demand are in high order.

In the Emblix Academy Digital marketing institute in KPHB, you will learn about all the major and minor modules of digital marketing, from Search engine marketing to Social Media Marketing and almost all Tools used for Digital Marketing.

Website: Digital Marketing Institute in KPHB


It Tears me Up Whenever we receive complaints from Clients About Their Experience With the Hackers They Met Before They Heard about us.
These Days There Are alot of Hackers Online, You Just Have to Be Careful about who you meet for help, because many people now don't know who to ask for help anymore but there's actually a solution to that which I am giving you for free, Don't go out there seeking for Hackers Yourself, Because the probability of getting a Real Hacker Out there Is Very Slim . ❌❌ ❌ Most Of Them are actually not who they say they're, they are just here to Rip people Off, You Can Always Identify Them With Their False Advertisements and False Testimonies Trying To Lure you Into their Arms, And most of them use yahoomails, gmails and other cheaper email providers which could easily expose their vulnerabilities, Please Don’t Fall For Them🚷 Come To Think Of It, Why would a Legit Hacker Be using a gmail or a cheap email provider that exposes his vulnerabilities????⚠️⚠️⚠️
Well, Our Purpose Here Is To Link You Up With Top Legit Hackers With Great Online Reputations and Impressive LinkedIn Profiles That’ll Blow Your Mind.

☑️ COMPOSITE FIRMWARE SECURITY SPECIALISTS is here to Provide you with The Best Hackers, So you can get saved from The Arms of the Fake Hackers❌❌.

☑️All our Specialists are well experienced in their various niches with Great Skills, Technical Hacking Strategies And Positive Online Reputations And Recommendations🔘
They hail from a proven track record and have cracked even the toughest of barriers to intrude and capture all relevant data needed by our Clients.

We have Digital Forensic Specialists, Certified Ethical Hackers, Software Engineers, Firmware Security Experts, Private investigators and more. Our Goal is to make your digital life secure, safe and hassle free by Linking you Up With these great Professionals such as JACK CABLE, ARNE SWINNEN, SEAN MELIA, DAWID CZAGAN, BEN SADEGHIPOUR And More. These Professionals are Well Reserved Professionals who are always ready to Handle your job with great energy and swift response so that your problems can be solved very quickly.
All You Need to Do is to send us a mail and we’ll Assign any of these specialists to Handle your Job immediately.

☑️ Below Is A Full List Of Our Services:
▪️ PHONE HACKING & CLONING (giving you 📱 Unnoticeable access to everything Happening on the Target’s Phone)
▪️BITCOIN MINING ⛏ And lot More.

🔘2021 © composite firmware specialists
🔘Want faster service? Contact us!
🔘All Rights Reserved ®️

Shawn philips said...

I lost my job few months back and there was no way to get income for my family, things was so tough and I couldn't get anything for my children, not until a met a recommendation on a page writing how Mr Bernie Wilfred helped a lady in getting a huge amount of profit every 6 working days on trading with his management on the cryptocurrency Market, to be honest I never believe it but I took the risk to take a loan of $800 and I contacted him unbelievable and I was so happy I earn $12,500 in 6 working days, the most joy is that I can now take care of my family I don't know how to appreciate your good work Mr. Bernie Doran God will continue to bless you for being a life saver I have no way to appreciate you than to tell people about your good services.
For a perfect investment and good strategies contact Mr Bernie Doran via WhatsApp :+1(424)285-0682 or Telegram : t.me/bernie_doran_fx Or Email : Bernie.doranfx01@gmail.com


🟢Binary scam recovery
🟢lost loan money recovery
🟢money laundry recovery
🟢Device hack
🟢Bank issues
🟢Access to school/company/fellowship/organization files
🟢Lost cars tracking
🟢fraud payment
🟢Access to cheating husband/wife device
🟢extending and subtracting of stamped file concerning a giving end line period of time
🟢tracing and recovering lost emails/conversations/contacts / and accessories

AS LOMG AS ITS TECHNOLOGY IT WILL BE HACKED , with firmwarehacks service you can get all of this and more done !!

❌ Binary Option, Forex and their likes are a means of making money but it’s more like gambling. There are no sure means to guarantee that a person could make profit with them and that’s why it can also be reasoned to be scam. Let’s not forget that some individuals even give you 💯 % guarantee of making profits and end up running away with your money. The internet today is full of Binary Option Recovery Scam, you see so much testimonies been shared about how a firm or Company helped them recover what they lost to Binary Options. But believe it, it’s just a way to lure more people and end up scamming them.

❌ You might have also come across some individuals that say they will give you guarantee on successful trades but they only end up as SCAMMERS as well. You here them say stuffs like 200% guaranteed in just 2 weeks and when you go into trade with them, they start telling you to pay profits percentage before you can get your income. These are all liars please avoid them. But if you have been a victim of this guys, then you should contact FIRMWARE now‼️

✳️The big Question is “Can someone Recover their money lost to Binary Option and Scam⁉️
I will say yes, and will tell you how.

The only way to Recovery your money back is by hiring HACKERS to help you break into the Firms Database Security System using the information you provide them with, Extract your file and get back your money. It seems like a really impossible thing to do, I will tell you, it should be impossible, but with the use of specially designed softwares known to HACKERS and Authorities (such as The FBI, CIA e.t.c) it is possible and the only way to recover your money.

✅FIRMWARE are a group of hackers who use their hacking skill to hunt down SCAMMERS and help individuals recovery their money from Internet SCAMMERS.
We just need the contact details of the SCAMMERS and Paymnet Info and within 4-8 hours your money will be return to you.

✳️ You can contact us via the emails below-:
2022 ©️ All right reserved ®️

Akshat Sharma said...

Before any phage can be studied, or used for its bacteriophage, it must first be isolated. As such, isolation is a critical step – indeed, the critical step – in many explorations of phage...

Sam Wichky said...

Thanks , your article is great . Download completely free fonts for your mobile phone and also for your computer to serve your work and interests.

Peeter said...


Hello to All !

We are offering all types of tools & Fullz on discounted price.
If you are in search of anything regarding fullz, tools, tutorials, Hack Pack, etc
Feel Free to contact

***CONTACT 24/7***
**Telegram > @leadsupplier
**ICQ > 752822040
**Skype > Peeterhacks
**Wicker me > peeterhacks


"Fresh Spammed SSN Fullz info included"
>>SSN FULLZ with complete info
>>CC With CVV Fullz USA
>>USA I.D Photos Front & Back
>>High Credit Score fullz (700+ Scores)
>>DL number, Employee Details, Bank Details Included
>>Complete Premium Info with Relative Info



=>Ethical Hacking Ebooks, Tools & Tutorials
=>Bitcoin Hacking
=>Kali Linux
=>Fraud Bible
=>Keylogger & Keystroke Logger
=>Whatsapp Hacking & Hacked Version of Whatsapp
=>Facebook & Google Hacking
=>Bitcoin Flasher
=>SQL Injector
=>Premium Logs (PayPal/Amazon/Coinbase/Netflix/FedEx/Banks)
=>Bitcoin Cracker
=>SMTP Linux Root
=>Shell Scripting
=>DUMPS with pins track 1 and 2 with & without pin
=>SMTP's, Safe Socks, Rdp's brute
=>PHP mailer
=>SMS Sender & Email Blaster
=>Server I.P's & Proxies
=>Viruses & VPN's
=>HQ Email Combo (Gmail, Yahoo, Hotmail, MSN, AOL, etc.)

*Serious buyers will always welcome
*Price will be reduce in bulk order
*Discount offers will gives to serious buyers
*Hope we do a great business together

===>Contact 24/7<===
==>Telegram > @leadsupplier
==>ICQ > 752822040
==>Skype > Peeterhacks
==>Wicker me > peeterhacks

as8836980@gmail.com said...

Mobile Phone Repair & Services Acharya Niketan Mayur Vihar Phase 1.tablet repair shop in mayur vihar phase Authorised Service Center – Samsung Mobile Service Centre in mayur vihar phase -1, for all your repairs, installations, battery issues, etc.

mesmerize spa & wellness said...

Massage Centres New Town, Kolkata - List of best Massage parlours, Body massage services New Town, Mesmerize Spa & Wellness. body spa in new town Kolkata. Opening at 11:00 AM. View MenuMake AppointmentCall nowGet directionsWhatsAppMessage usContact UsGet QuoteFind.

mesmerize spa & wellness said...

I believe a good massage is something that will put you into a deep sleep, Body massage in Kolkata Newtown releasing all the stress from the body.Spa-Massage Service / Your Location (Newtown - Kolkata) female to male body massage service in kolkata newtown

mesmerize spa & wellness said...

Kolkata is providing good spa houses, where The Thai Spa(Kolkata) is providing best services in the city. Kolkata body massage parlour Its interiors provide good relaxations mood, where .