President Biden on October 28 announced a “Build Back Better” framework that outlines spending provisions described as costing $1.75 trillion over 10 years and revenue offsets believed to add up to nearly $2 trillion over the same period. The proposed revenue offsets include significant business, international, and individual tax increases, increased IRS enforcement measures, and repeal of a Medicare prescription drug rebate rule.
The revised bill’s significant business and international provisions include a new 15% corporate profits minimum tax on large corporations, a new 1% tax on corporate stock repurchases, limitations on interest deductions of international financial reporting groups, modifications to inbound and outbound international provisions -- including global intangible low-taxed income (GILTI), foreign-derived intangible income (FDII), foreign tax credit rules, the base erosion and anti-abuse tax (BEAT), and subpart F income -- and the extension of expensing (i.e., current deduction) of research and experimental costs under Section 174 through the end of 2025.
Our PwC Tax Insights provides an analysis of key business and individual provisions proposed as part of the revised Build Back Better bill and includes a chart summarizing effective dates in the bill.
