Green Book: Observations & Insights

Understanding the tax proposals in the Biden administration's budget for FY2022

Manal Corwin

Manal Corwin

Principal in Charge, Washington National Tax, KPMG US

+1 202-533-3127


On May 28, 2021, the Biden administration transmitted to Congress its budget recommendations for fiscal year (FY) 2022, and the U.S. Treasury Department released the “Green Book”—a 114-page explanation of the tax proposals in the budget. The Green Book outlines the administration’s proposals in greater detail than seen before, including information on effective dates, revenue estimates, and design choices. Following are resources from the KPMG Washington National Tax practice that analyze potential implications for business taxation.

For recent developments regarding Biden administration tax legislation, visit KPMG TaxNewsFlash—Biden Tax Agenda.


Analysis and Observations of Tax Proposals in Biden Administration’s FY 2022 Budget

May 31, 2021

KPMG Report | KPMG analysis of the Biden administration’s tax proposals provided in the General Explanations of the Administration’s Fiscal Year 2022 Revenue Proposals document prepared by the Department of the Treasury, released on May 28, 2021. This analysis includes observations on what the Biden proposals might mean for taxpayers, observations on what the proposals include, and often observations on what they do not.


Red Light, Green Book: The Anti-Inversion Proposals

June 30, 2021

KPMG Inside International Tax podcast | Part 3 of our series on the Green Book delves into its sweeping new anti-inversion provisions. Amid continued concern with U.S.-based companies inverting into foreign jurisdictions, the Green Book resurrects the ghosts of past proposals to tighten the screws still further. This podcast describes the potential impact of these provisions on acquisitions of U.S.-based companies. [31:53]

Green Green Grass of Home: The Outbound Perspective of the Green Book

June 22, 2021

KPMG Inside International Tax podcast | In part 2 of our series on the Biden administration’s Green Book, the focus shifts to outbound provisions. This podcast walks you through the Green Book’s outbound proposals—in particular GILTI regime changes—and describes potential ramifications for U.S.-based multinationals. [43:28]

Greener on the Other Side? The Inbound Perspective of the Green Book

June 15, 2021

KPMG Inside International Tax podcast | After much anticipation, the Biden Administration showed its cards General Explanations of the Administration’s Fiscal Year 2022 Revenue Proposals (Treasury’s Green Book), which provided beach reading for tax professionals over Memorial Day weekend. This podcast walks through the Green Book’s inbound company tax proposals and how they might affect these companies. [40:59]

Biden’s Budget Proposals: It’s Not Easy Being Green

May 25, 2021

KPMG Catching Up on Capitol Hill podcast | The Biden Administration’s forthcoming budget will include a “Green Book”—a more detailed explanation of its tax proposals. How important is this Green Book to the tax legislation being contemplated by Congress? Listen to this podcast to learn more about the history of Green Book proposals becoming law, the relevance of this year’s version, effective dates and more. [14:24]

KPMG reports on the Green Book by industry and taxpayer

Biden's Tax Plan and Real Estate

June 4, 202

KPMG What's News in Tax | If the tax provisions described in the Green Book are enacted into law, the real estate industry (e.g. sponsors, developers, investors, and others) will have a lot to think about. This article outlines the potential changes and impact on these taxpayers.

More reports and articles

More Sledgehammers, Fewer Flies: The Green Book's Anti-Inversion Proposals

July 26, 2021

In this article, which appeared in Tax Notes Federal, the authors explain how the Biden administration’s proposals to amend section 7874 could affect commonly structured foreign acquisitions of U.S. businesses, and they recommend changes and clarifications to better achieve the goals of those anti-inversion proposals.

Treasury Releases the American Families Plan Tax Compliance Agenda

June 14, 2021

KPMG Report | Treasury's Green Book further describes the Biden Administration's proposals related to tax compliance, a comprehensive plan providing IRS funding for enforcement activities. This KPMG article discusses this potential marked uptick in enforcement activity that may affect many types of taxpayers.

Planning in Advance for the Biden Administration’s Proposed Increased Tax Rates

June 14, 2021

KPMG Report | As outlined in Treasury’s Green Book, the Biden Administration proposes that the requested corporate rate increase become effective for tax years beginning after December 31, 2021. This article summarizes common “reverse” planning opportunities for accelerating income and deferring deductions through accounting method changes, elections, and transactional planning.