This part of the proposal, which could be called the ‘Amazon Tax’, is to impose a 15% minimum tax on corporations with book income of over $1 billion. Accounting principles allow differences in what is reported for book purposes and what is reported for tax. These are largely timing differences, and the company must account for the deferred taxes. However, this acceleration of tax would raise tax revenue by about $320 billion. This would reduce the cash flow of the 1,000 or so companies with book income over $1 billion.
This could be called the ‘Apple Tax’ since Apple famously moved intellectual property to Ireland at a remarkable 2% tax rate. BBB proposes to enforce and increase the GILTI tax and reform international taxation. GILTI seems to affect about 120 of the S&P 500, primarily technology and finance companies. This change raises $280 billion.
