#23.11 [english]: Proposed Legislation – U.S. retaliation against (German?) extraterritorial taxation

In this TAXpod episode, we discuss upcoming U.S. legislation
under the “Defending American Jobs and Investment Act” and the
proposed section 899. Our special guest is Loren Ponds,
partner with Miller & Chevalier in Washington D.C., who is
guiding us through the announced changes. The proposed sec.
899 introduces increased tax rates (up to 20%) on companies with
business in the U.S. which are headquartered in countries that
impose extraterritorial or discriminatory taxes, and is meant to
be a retaliatory measure against such countries. With the
proposed rule, the U.S.A. target some country’s “Undertaxed
Profits Rules”, “Digital Services Taxes” and – this being the
reason for addressing this issue in a German podcast –
  presumably Sec. 49 of the German Income Tax Act. As a
result, the application of Sec. 49 could have a much wider impact
– even on taxpayers who have nothing to do with Sec. 49 – than
was generally expected in Germany. It should not be
underestimated that the USA is not only a defensible democracy,
but also a defensible tax juristdiction that will prevent
extraterritorial taxation, if necessary without shying away from
confrontation… Enjoy listening!
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