Brad Setser
speaker
466 appearances
2 recordings
1 series
first heard Nov 2024
last heard Apr 2025
Brad Setser’s voice in public audio — every appearance, attributed to the second.
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Appearances
And the foreign derived intangibles income tax or FITI goes up to the god awful high rate of sixteen percent.
So there there are some ratchet ups.
Um so what happened with the Tax Cuts and Jobs Act?
First of all, the corporate side was a total revolution.
Before the Tax Cuts and Jobs Act, the US had a system called deferment.
A deferral, where profits earned abroad in theory were taxed at the US headline tax rate of 35, but only if the profit was returned to the United States.
Profits were never returned to the U.S.
Companies borrowed against their offshore profits.
And that was essentially a system that sort of worked.
But it meant that US companies had on the U.S.
side of their balance sheet a lot of debt, and on the foreign side of their balance sheet a lot of assets.
It wasn't great.
So the main thing the Tax Cuts and Jobs Act did was it got rid of deferral.
You pay tax as you go.
You pay your US tax, you're free to move your money wherever you want.
That was supposed to bring a lot of money back.
It obviously lowered the headline tax rate from 35 to 21.
It created this new global minimum on intangibles, which is sort of a strange concept, but essentially intellectual property, that everyone pays on their global income.
So in theory, it's now territorial, but it's not entirely.
And then it created
Showing 241–260 of 466 · page 13 of 24
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