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Update on the Revenue Effects of GILTI and FDII, 2026 Rate Changes, and Proposed Policy Reforms

We analyze new data from the US Treasury to examine historical revenue effects of TCJA’s international corporate tax provisions. We also provide updated conventional estimates to assess the revenue impact of scheduled 2026 rate increases on foreign income of US corporations and assess several proposals that aim to further increase tax revenue.

Update on the Revenue Effects of GILTI and FDII, 2026 Rate Changes, and Proposed Policy Reforms

Taxing Foreign Affiliates of U.S.-Domiciled Firms

We explain how the PWBM uses its dynamic Overlapping Generation (OLG) model to analyze tax policies affecting foreign-earned income by affiliates of U.S.-domiciled firms. We evaluate two illustrative policy changes: we show how firms’ tax liabilities and the allocation of capital between domestic and international production are affected by an increase in foreign tax rates and a decrease in U.S. tax exemptions on foreign-derived income.

Taxing Foreign Affiliates of U.S.-Domiciled Firms

The End of the Double Irish: Implications for US Multinationals and Global Tax Competition

After Ireland ended the Double Irish tax planning strategy in 2020, US firms with historical links to Ireland have shifted their intellectual property (IP) away from traditional tax havens to Ireland and the US to take advantage of tax incentives offered by both countries. This has coincided with a significant increase in Irish corporate tax revenue, particularly for less capital-intensive firms. Repatriation of foreign earnings to the United States has also increased, but fiscal benefits to the US have been offset by tax incentives passed under TCJA.

The End of the Double Irish: Implications for US Multinationals and Global Tax Competition

Biden’s SAVE Plan – Distributional Impact Analysis

The impact of income-driven repayment (IDR) educational financing plans by income, race, and gender is not generally well understood. Our analysis estimates that approximately 43 percent of the subsidies from President Biden’s Saving on a Valuable Education (SAVE) plan will accrue to current Black student borrowers and 71 percent to current female borrowers. While lower- to middle-income student borrowers stand to gain the most, we estimate that about a fifth of the benefits will go to households in the top 20 percent of the income distribution, and borrowers with graduate-level education who benefit from the SAVE plan tend to experience the highest savings on average.

Biden’s SAVE Plan – Distributional Impact Analysis