Legal Alert: An incomplete picture: Democratic senators release “framework” for international tax overhaul
On August 25, 2021, Senate Finance Committee members Wyden, Brown, and Warner released draft bill language and a section-by-section summary of their proposed International Tax Reform Framework. The legislative language is generally in line with the International Tax Overhaul proposals first released by the Senators on April 5, 2021. The draft legislation includes some provisions similar to provisions that were included in the Green Book released by Treasury on May 28, 2021, including, in particular, modifications to the Global Intangible Low-Taxed Income (GILTI) rules that were enacted as part of the 2017 Tax Cuts and Jobs Act (TCJA). But, in so doing, it makes certain departures from the “Pillar II” minimum tax proposals under consideration at the OECD. The proposed legislation also differs from the Green Book proposals in its approach to amending the Foreign Derived Intangible Income (FDII) provision and the Base Erosion Anti-Abuse Tax (BEAT), which also were enacted as part of the TCJA.
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