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Eliminating Excess Benefits from the Section 199A Deduction: Options for Reform under TCJA Extension

The deduction for pass-through income under section 199A provides a benefit in excess of 20 percent (“excess benefit”) for some taxpayers due to its interaction with the progressive tax rate system. As Congress considers extending 199A beyond 2025, options to remove the excess benefit while maintaining the 20 percent tax benefit could raise between $46B and $178B over the 10-year budget window, depending on design.

Eliminating Excess Benefits from the Section 199A Deduction: Options for Reform under TCJA Extension

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