Delay the requirement to amortize research and development (R&D) expenses over five years, instead of taking immediate deductions, to begin after 2025 instead of after 2021.Modify the base erosion and anti-abuse tax (BEAT) for multinational corporationsĬreate a new limitation on foreign company base sales and services income Reduce the deduction for Foreign-Derived Intangible Income (FDII) to 21.875 percent, resulting in a tax rate of 15.8 percent, effective for tax years beginning after December 31, 2022Ĭreate a new limitation on interest expense deductions for certain multinational corporations, effective for tax years beginning after December 31, 2022 Include foreign oil and gas extraction income (FOGEI) Reduce the foreign tax credit (FTC) haircut to 5 percent and allow FTCs to be carried forward for 5 to 10 years and disallow FTC carrybacksĮxempt GILTI from expense allocation rules Reduce the deduction for Qualified Business Asset Investment (QBAI) to 5 percent Reduce the deduction for GILTI to5 percent, resulting in a tax rate of 15 percentĬalculate GILTI on a country-by-country basis Excluded from the tax are stock contributed to retirement accounts, pensions, and employee-stock ownership plans (ESOPs).Ĭhange the Global Intangible Low-Taxed Income (GILTI) regime, effective for tax years beginning after December 31, 2022, including: Impose a 15 percent minimum tax on corporate book income for corporations with profits over $1 billion, effective for tax years beginning after December 31, 2022Ĭreate a 1 percent excise tax on the value of stock repurchases during the taxable year, net of new issuances of stock, effective for repurchases after December 31, 2021. Make permanent the active pass-through loss limitation enacted in the 2017 Tax Cuts and Jobs Act (TCJA) For 2031, the SALT deduction cap would be set at $10,000.Įxpand the base of the 3.8 percent Net Investment Income Tax (NIIT) to apply to active business income for pass-through firms The $80,000 SALT cap amount would also apply to the 2021 tax year. Raise the cap on the state and local tax (SALT) deduction from $10,000 to $80,000 and extend this cap through 2030.Limit Individual Retirement Accounts (IRAs) contributions when balances reach $10 million and accelerate required minimum distributions for those accounts.Extend the ARPA’s temporary expansion of the Earned Income Tax Credit (EITC) eligibility, phase-in rates, and amount through 2022.
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