Assessing U.S. Global Tax Competitiveness after Tax Reform

This paper assesses the impacts of the 2017 tax reform act on U.S. competitiveness in terms of changes in incentives for U.S. domestic corporate investment and the taxation of U.S.-headquartered companies and their foreign subsidiaries relative to foreign-headquartered companies. The reduction of the U.S. statutory tax rate has significantly improved domestic investment incentives as measured by marginal and average effective tax rates, assuming an average use of debt and equity. In addition, the partial adoption of a participation exemption system in some cases can allow U.S. companies now to compete globally on equal tax terms with foreign-headquartered companies. However, a new U.S. global minimum tax imposes current taxation on certain foreign income previously eligible for deferral and, as a result, may disfavor U.S. ownership of high-return foreign assets relative to foreign-headquartered companies. Average effective tax rates are also reduced by a new domestic incentive for undertaking high-return investments in the United States. Even so, U.S. research incentives continue to lag behind those available in many other major countries, taking into account special deductions, tax credits, and patent box regimes.