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As the debate begins over President Biden’s corporate tax increases, the temptation will be to focus on the headline tax rates. Those rates are bad enough, but worse lurks in the details. For one important example, dive into Mr. Biden’s plan for taxing U.S. companies’ global profits.

We’re talking about the tax on global intangible low-tax income, known as Gilti, which was created by the 2017 tax reform. American multinationals were previously charged the full U.S. corporate tax rate on their global profits, but only when they repatriated their foreign earnings. That created a strong incentive to park foreign profits overseas. Gilti taxes many foreign profits as they arise, but at half the top domestic rate. That less punitive approach allowed more companies to return overseas cash to the U.S.

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