Q&A: US tax reform

The latest US tax proposals under the ‘One Big Beautiful Bill’ includes a suite of income tax changes that may reshape the tax landscape for globally mobile individuals and multinational organisations. These changes are intent on promoting domestic economic growth and combating perceived foreign tax advantages consistent with policy objectives. Other proposals represent a departure from some long-established US international tax principles that could introduce significant complexity and cost for globally mobile individuals and the organisations that support them. In particular a proposed hike in the top marginal rate and proposed provisions where foreign tax regimes are perceived to be unfairly treating US taxpayers and corporations is a shift away from a perceived ‘norm’.

At the bill’s core are proposed tax increases targeting income earned outside the US pressure points for cross-border compensation structures especially in years of arrival and departure and corporate policy...