After much anxious anticipation, the Biden administration finally showed its cards. The Treasury Department’s General Explanations of the Administration’s Fiscal Year 2022 Revenue Proposals (the “Green Book”) provided a bit more detail about the provisions that had been previewed several months earlier in Biden’s Made in America Tax Plan. Of particular note were a variety of provisions that will affect foreign multinationals doing business in the United States.
This podcast (Part 1 of a three-part series) walks you through the Green Book’s “inbound” proposals—the SHIELD and the disproportionate interest limitation—and describes how they might affect investment and other decisions for inbound companies. For example, why might the SHIELD have a bigger impact on inbound companies than the BEAT? How does the new limitation on deducting interest target foreign-parented U.S. groups? How do both these proposals interact with the ongoing OECD negotiations on Pillar One and Pillar Two?
Our host Gary Scanlon interviews KPMG Washington National Tax professionals (and former Treasury officials) Danielle Rolfes and Douglas Poms about the Green Book tax plans salient to inbound corporations.
Listen to Part 2, Green Green Grass of Home: The Outbound Perspective of the Green Book
Listen to Part 3, Red Light, Green Book: The Anti-Inversion Proposals