Global minimum tax

The proposal would revoke Base Erosion and Anti-Abuse Tax liability, replacing them with an “undertaxed profits rule”. In combination with the GILTI regime, the rule would guarantee that income earned by a multination company, whether parented in the US or elsewhere in the world, is subject to a minimum rate of taxation regardless of the place where the income is earned.

Carried interest loophole

A “carried interest” is the contractual right of a hedge fund manager to a share of a partnership’s profits. At the present, it’s taxable at the capital gains rate if certain conditions are met.

The new 2024 tax plan proposes to close this loophole.