G7: Rich nations back deal to tax multinationals

That would be imputed income passed on to employees.

That’s an incorrect description of the budget reconciliation process.

One of the budget reconciliation categories is explicitly for revenue, which means being revenue-neutral would make it harder to pass under reconciliation.

Being an aspect that explicitly impacts revenue makes it much easier to pass under the revenue reconciliation process. In fact, adjusting those rates would be a pretty straight-down-the-middle use of reconciliation.

https://en.m.wikipedia.org/wiki/Reconciliation_(United_State...

But these arrangements are clearly fake to avoid tax. There are already laws that see through it, just there is nobody that would dare to do anything about it. In the UK for example, for a long time people paid themselves in loans, to completely avoid tax. This was at first available only to the rich, HMRC knew about it and did nothing. Only when the "pleb" learned about it and started using it, they woke up and applied the tax retrospectively and called it "disguised remuneration". Many people lost everything they had, many committed suicides.

Why HMRC does not do the same with companies using fake charges to hide profits? Those companies got huge competitive advantage over local small companies who cannot afford such creative accounting. So many businesses didn't happen because of that.

I think it's time HMRC doubled down and destroyed this gravy train.

I am sure we have clever people that would build a new Facebook, that is ethical and pays taxes.

I'm not sure what you mean here. You can't write off a mortgage. You could write off interest, but not the value of the mortgage.

Real estate tends to appreciate in value, especially in cities. The company would have to get unlucky with their real estate to be able to write off a loss. Buildings don't usually depreciate.

They could allow their buildings to fall into a state of disrepair, hoping it would lower their value. But why would they? The can deduct the repairs. It's a legitimate expense.

> They can make all the agreements they want, but it's not a legal treaty until 2/3 of the Senate agrees

That's not true under international law. The confusing thing here is that "treaty" means different things under international law and US law.

Under international law, any legally binding agreement between two countries is a treaty.

Under US law, there are three types of agreements between the US and foreign states (or international organizations): treaties, congressional-executive agreements, and sole executive agreements. The first are approved by two-thirds vote in the Senate, the second by an ordinary Act of Congress, the third by the President acting alone (without Congressional involvement.) But all these three are considered equally to be treaties under international law. The distinction between the three is purely a US domestic law distinction. Article 46 of the Vienna Convention on the Law of Treaties says that domestic law does not determine the validity of treaties under international law unless the violation is manifest, which means that for most purposes the rest of the world can just ignore this US-internal distinction.

The authority to ratify treaties, in the international law sense of "ratify" and "treaties", solely belongs to the President (and the Secretary of State, and ambassadors, acting on the President's behalf). When the US constitution speaks of "ratifying" a treaty by the Senate, that is not ratification under international law. That's actually a domestic US legislative procedure which confusingly happens to have the same name.

> many laws affecting jurisdiction, accounting standards, and the tax laws themselves. None of this can be done with an executive agreement.

In practice this will likely be done by an ordinary Act of Congress (a "congressional-executive agreement") which only requires an ordinary (not two-thirds) vote in the Senate.

However, one needs to understand that ratifying a treaty under international law, and passing domestic legislation to implement it, are independent things. Under international law, the President or Secretary of State can legally submit the instrument of ratification for the treaty even if Congress hasn't passed any implementing legislation. International law doesn't care about implementation legislation, that's a domestic law concern. Now in practice the President or Secretary of State wouldn't do that, because that is not the traditional practice of the US. But other countries in the world do sometimes ratify treaties before the implementing legislation is passed. That generally happens in systems – whether Westminster democracies or non-democracies – in which the executive can be confident they'll get the implementing legislation passed.