A1 · Pillar A · Revenue Optimization
Corporate tax modernization
Restructure the federal corporate income tax to align with OECD Pillar Two minimum standards over a medium-term horizon, including GILTI reform as a country-by-country qualifying minimum tax, interest-deductibility limits, and tighter base-erosion rules. Full international alignment is contingent on administrations supportive of coordination; domestic GILTI and minimum-tax components can proceed independently.
- 10-year fiscal
- +$950BRevenue
- Implementation
- Years 1–7
- Middle class
- Positive
- Planetary
- Neutral
$700B–$1.2T · Medium confidence
Shields labor income from compensating tax increases. No new wage rates below $400,000.
No material climate effect.
Global precedent
OECD Inclusive Framework Pillar Two, with over 140 participating jurisdictions and about 60 implementing the 15 percent global minimum in 2024–2025. Early-implementation jurisdictions show reduced profit-shifting and modest increases in domestic corporate tax revenue.
Lead mechanism
Treasury; Senate Finance; House Ways and Means.
Bipartisan framing
Conservative case
Levels the global playing field for U.S. firms competing against companies based in tax havens; reduces incentives for inversions.
Progressive case
Ensures large corporations pay a meaningful share of federal taxation.
The OECD framework was negotiated under the prior Trump administration and reflects U.S. competitiveness interests.
Figures in this framework are illustrative directional estimates derived from publicly available data and conventional Congressional Budget Office budget-window logic. They are not official CBO scores. Any provision adopted from this framework would require formal CBO scoring before legislative consideration. This document is a policy white paper, not an introduced bill.