The minimum tax in this plan is much stronger than the TCJA minimum tax; TCJA's min tax exempts first 10% return, allows blending, and is at half the US rate.
Biden unveils plan to penalize companies that offshore jobs ahead of Michigan visit https://thehill.com/homenews/campaign/515597-biden-unveils-plan-to-penalize-companies-that-offshore-jobs-ahead-of#.X1kIJL6CIh8.twitter
Biden unveils plan to penalize companies that offshore jobs ahead of Michigan visit https://thehill.com/homenews/campaign/515597-biden-unveils-plan-to-penalize-companies-that-offshore-jobs-ahead-of#.X1kIJL6CIh8.twitter
As I've argued extensively elsewhere, TCJA's min tax is effectively an "America last" tax policy, since both haven income and other foreign income is tax preferred to US income. https://www.americanprogress.org/issues/economy/reports/2020/01/30/479956/options-international-tax-policy-tcja/
TCJA saw that offshoring and profit shifting were a problem, but made the problem worse in several respects, including new offshoring incentives.
https://journals.library.columbia.edu/index.php/taxlaw/article/view/6840
https://journals.library.columbia.edu/index.php/taxlaw/article/view/6840
Evidence indicates that companies with the largest TCJA tax break actually invested more abroad, not in the United States.
https://tax.unc.edu/index.php/publication/the-effect-of-the-tax-cuts-and-jobs-act-of-2017-on-multinational-firms-capital-investment-internal-capital-market-frictions-and-tax-incentives/
https://tax.unc.edu/index.php/publication/the-effect-of-the-tax-cuts-and-jobs-act-of-2017-on-multinational-firms-capital-investment-internal-capital-market-frictions-and-tax-incentives/
The Biden minimum tax raises rate to 21 percent, applies country-by-country, and doesn't allow a ten percent tax free return abroad. Some other provisions (investment tax credit, surtax) are more difficult to implement, but remain FAR more targeted at the objective than TCJA.
Despite the purported objectives of TCJA, there was no discernible increase in investment, and workers never saw the promised wage gains. Likewise, "America first" trade policy has only backfired, harming American farmers, manufacturers, and consumers. https://www.foreignaffairs.com/articles/united-states/2019-10-15/progressive-case-against-protectionism