Part 2 of our series discussing the Biden administration Treasury Department’s General Explanations of the Administration’s Fiscal Year 2022 Revenue Proposals (the “Green Book”) shifts its focus to the Green Book’s "outbound" provisions. The TCJA resulted in dramatic changes to the landscape for U.S. multinationals with operations overseas, and the Green Book proposes additional changes to the taxation of income earned offshore.
This podcast walks you through the Green Book’s outbound proposals. For example, how would a country-by-country approach to GILTI work in a world with no foreign tax credit carryforwards or carrybacks? What about subpart F? And, how are the Biden proposals informed by the ongoing OECD negotiations on 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 outbound corporations.
Listen to Part 1, Greener on the Other Side? The Inbound Perspective of the Green Book
Listen to Part 3, Red LIght, Green Book: The Anti-Inversion Proposals