HILL TAX BRIEFING: Global Tax Deal Faces Congressional Buzzsaw

July 26, 2022, 10:03 AM UTC

Congressional approval of at least one part of the OECD-led global tax deal is in jeopardy after Sen. Joe Manchin (D-W.Va.) said he wouldn’t back tax hikes in reconciliation due to inflation.

The global minimum tax, known as Pillar Two, would have required only a simple majority in the Senate for passage if included in reconciliation, but Manchin’s opposition has scrambled those plans.

Administration officials continue to speak optimistically about participation in the global pact, but neither the minimum tax nor Pillar One, which deals with profit reallocation for multinationals, has an obvious path forward in Congress.

Pillar One may have a tougher path: Republicans say it needs to two-thirds approval in the Senate since it would override already existing tax treaties.

“The Constitution doesn’t say that treaties are sort of confirmed by the Senate at the discretion of executive,” Sen. Pat Toomey (R-Pa.) told Bloomberg Tax. “That’s not how it works. They don’t have any such authority.”

Uncertainty in the US, which hosts many of the companies affected by the potential new tax regime, would cast a shadow as the rest of the world works to hash out the details.

“You have a cohort of companies that are going, ‘Wait and minute, I didn’t start this, why am I being dragged into this?’” said Rohit Kumar, co-leader of PwC’s Washington national services tax practice and a former senior aide to Senate Minority Leader Mitch McConnell (R-Ky.), on Pillar One.

Colin Wilhelm has more.

More on the Global Tax Deal: The OECD will hold a public feedback forum on its most recent draft of its profit relocation mandate on Sept. 12, Isabel Gottlieb reports.

Joint Committee on Taxation Report

A report from the Joint Committee on Taxation Congress’s found President Joe Biden’s proposed budget for fiscal year 2023 would raise $1.7 trillion over 10 years, albeit without a revenue estimate of Biden’s proposal of a minimum tax for taxpayers worth more than $100 million that would include taxing unrealized gains.

JCT also estimated a key international tax proposal on fighting profit-shifting would raise $318.7 billion over 10 years. Under that proposal, the US would replace its current anti-profit-shifting system—the base erosion and anti-abuse tax—with the undertaxed profits rule, which is part of the rules that were agreed to by nearly 140 countries as part of the global tax deal.

Under the undertaxed profits rule, countries can apply the global agreement’s 15% minimum tax rate to a company operating within their jurisdiction when the company is paying less than 15% somewhere else and its home country isn’t already applying the minimum tax. The global agreement’s undertaxed profits rule is part of an effort to ensure that companies pay at least 15% everywhere, thus eliminating the incentive for a company to move its profits from one country to another in search of the lowest tax rate.

Read more from Naomi Jagoda.

Crypto

A markup of legislation to regulate stablecoins was delayed by the House Financial Services Committee.

The proposal would grant the Federal Reserve authority to allocate licenses to stablecoin distributors and require that the entirety of reserves to be high-quality liquid assets or cash. Those elements are subject to change as Chairwoman Maxine Waters (D-Calif.) and ranking member Patrick McHenry (R-N.C.) are discussing a new version of the bill.

This comes as the Commodity Futures Trading Commission indicates that it will ramp up its policing of the crypto market.

“Make no mistake: we will use all levers at our disposal, and all relevant authorities to continue rooting out fraud and manipulation,” CFTC Chairman Rostin Behnam said Monday.

Read more from Evan Weinberger and Allyson Versprille, as well as Alex Nguyen.

Small Transactions: Crypto owners wouldn’t have to report transactions worth less than $50 under a bill sponsored by Sens. Toomey and Kyrsten Sinema (D-Ariz.).

Transactions where there is less than $50 in gain would also be exempt. The bill contains provisions to prevent crypto owners evading reporting laws by splitting large transactions up into smaller ones that would slide under the $50 threshold.

Laura Davison has more.

Chips Bill: For clues as to whether a one-time $52 billion expenditure and tax breaks are enough to jump start domestic production of chips when manufacturing has been moving off-shore for decades, look at what has worked for Taiwan, the largest semiconductor chip producer.

Read more from Bloomberg Tax columnist Andrew Leahey, as well as Laura Litvan.

What to Watch Today

Federal Reserve: The American Enterprise Institute holds a Tuesday panel discussion on the Federal Reserve.

Beyond the Beltway

Abortion: Georgia’s recently passed anti-abortion law has prompted questions as the law recognizes unborn children as dependents for tax purposes. However, the law doesn’t specify what kind of benefits taxpayers would be eligible for under this new framework. The Georgia Department of Revenue will be publishing guidance to address this, a department spokesperson said.

Read more from Michael J. Bologna.

— With assistance from Michael Rapoport and Joe Stanley-Smith.

To contact the reporter on this story: Richard Tzul in Washingon at rtzul@bloombergindustry.com

To contact the editors responsible for this story: Butch Maier at bmaier@bloombergindustry.com; Alex Clearfield at aclearfield@bloombergindustry.com

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