Both House and Senate tax reform drafts include measures that are popularly being referred to as a US ‘patent box’. A patent box (also: innovation box; IP box) is in essence a special low tax rate applied to income generated by certain types of IP. As such, patent boxes may be viewed as high tax countries’ answer to tax havens – and even with a tax rate down to 20% the US would still be more a high tax country than a tax haven. IP that has been moved to a tax haven has the potential to divert valuable tax revenue away from where the IP originated. Given the amount of valuable IP that is undeniably being created in the US – and the corresponding level of IP held in tax havens outside the US,
The long awaited US tax reform bill has been released by House Republicans. Media reports suggest that Democrat support will not to be needed to get it passed, because of the limited impact on the deficit – that is estimated at $1.5tn over 10 years. It contains some very significant changes for international business. One As anticipated, the corporate tax rate would be reduced from the current 35% down to just 20% starting in 2018. This is seen as a major boost to American companies’ international competitiveness and to American jobs. Two While dividends from foreign companies are taxable under the current US rules, the bill introduces a full exemption for dividends from 10% foreign subsidia
