Last month, Senate Finance Committee Chair Ron Wyden of Oregon and fellow Finance Committee Democrats Sherrod Brown of Ohio and Mark Warner of Virginia released a draft proposed overhaul of the international tax regime (the “Wyden Proposal”). The Wyden Proposal would make significant changes to key aspects of the 2017 Tax Cuts and Jobs Act, including changes to the GILTI, BEAT and FDII regimes. The Wyden Proposal would also make sweeping changes to the calculation and availability of foreign tax credits. However, the proposal leaves a number of key tax rates blank—presumably to provide flexibility for the legislative process and meeting budgetary targets.
