On 11 March 2024, the U.S. Department of the Treasury declared that it published the General Explanations of the Administration’s Fiscal Year 2025 Revenue Proposals  or the “Greenbook,” in which it detailed the revenue proposals included in President Joe Biden’s budget. The Greenbook outlines critical tax proposals that will support President Biden’s investments in the American people by ensuring the wealthy and large corporations pay their fair share, lowering costs for hard-working families, and further reducing the deficit.

The Administration’s revenue proposals would ensure that the wealthy and large corporations pay their fair share and, in doing so, fully pay for the investments proposed in the President’s Budget while generating roughly $3 trillion in additional deficit reduction over the next decade. The proposals would also lower costs by expanding key tax credits for workers and families.

The main revenue proposals in the Greenbook are as follows:

Reform Business Taxation

• Raise the corporate income tax rate to 28%;
• Increase the corporate alternative minimum tax (CAMT) rate to 21%;
• Tax corporate distributions as dividends;
• Limit tax avoidance through inappropriate leveraging of parties to divisive reorganizations;
• Increase the excise tax rate to 4% on repurchase of corporate stock and close loopholes;
• Limit losses recognized in liquidation transactions;
• Conform definition of “control” with corporate affiliation test;
• Prevent basis shifting by related parties through partnerships;
• Expand limitation on deductibility of employee remuneration in excess of USD 1 million;
• Prevent prison facility rent payments from contributing to qualification as a REIT;
• Strengthen limitation on losses for noncorporate taxpayers.

Reform International Taxation

• Revise the global minimum tax regime, limit inversions, and make related reforms;
• Repeal the deduction for foreign-derived intangible income;
• Adopt the undertaxed profits rule;
• Revise the rules that allocate Subpart F income and GILTI between taxpayers to ensure that Subpart F income and GILTI are fully taxed;
• Limit foreign tax credits from sales of hybrid entities;
• Require a controlled foreign corporation’s taxable year to match that of its majority U.S. Shareholder;
• Restrict deductions of excessive interest of members of financial reporting groups;
• Conform scope of portfolio interest exclusion for 10-percent shareholders to other tax rules;
• Expand access to retroactive qualified electing fund elections;
• Treat payments substituting for partnership effectively connected income as U.S. source Dividends;
• Provide tax incentives for locating jobs and business activity in the United States and remove tax deductions for shipping jobs overseas;
• Reform taxation of foreign fossil fuel income.

Additional revenue proposals include support for urban and housing development, adjustments to energy taxes, increased tax rates for high-income earners, improvements in tax compliance and administration, and aid for workers, families, and economic stability.