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Regular-article-logo Tuesday, 07 April 2026

Tax reform Trump-style

The US president is not just entertaining; he has a few ideas

Writing On The WallAshok V. Desai Published 14.03.17, 12:00 AM
Whether it is his shining hair, his scurrilous abuse or his puppet-like gestures, Trump has breathed 
new life into TV entertainment 

America has been the home of entertainment since the coming of the movies. But they were indigenized in India by the 1930s. Our film industry overtook all others in terms of output by the 1980s. Our politicians, nurtured in the anti-British movement, were rather heroic and virtuous, and took some time to learn the ropes. But the last nationalist generation had passed by the 1970s; after that, our politicians have been as human and entertaining as anywhere else. So it is a long time since we looked abroad for amusement.

But Trump changed all that. Whether it is his shining hair or wig, his scurrilous abuse or his puppet-like gestures, he has breathed new life into TV entertainment. He acts so well that it is easy to forget that he has a few ideas, ideals and ambitions. One is to send Indian engineers packing and take American jobs back for Americans. We have just seen the first consequence in the murder of Srinivas Kuchibhotla in Kansas City.

But Trump does not just want to throw Indian techies out; he also wants to stop American companies from outsourcing work to India. The first is well within his reach; all he has to do is to stop issuing work visas. The second is more difficult. But people have been working on it, and proposals are ready. One of them is to replace the current way of taxing incomes by what has been called the destination-based cash flow tax. The name is so long that it is routinely shortened to DBCFT. As far as I can understand, DBCFT will subsidize domestic labour costs and exports, and tax imports. It can thus be thought of as a combination of a tariff and a wage subsidy confined to indigenes.

Most countries tax profits that arise from business operations within their territory. The subsidiary of an American company in India, for instance, would pay corporate income tax in India on the profits it makes in India, just like an Indian-owned company. Similarly, the American subsidiary of an Indian company would pay tax in the US on its profits. Eric Toder of the Tax Policy Center calls this a territorial tax because it is tax on profits arising in the taxing country's territory. He distinguishes it from a worldwide tax, which would in addition tax profits that are earned abroad; tax paid abroad on those profits would be deducted from the tax liability. He distinguishes a third category, destination-based tax, which would tax profits on goods and services consumed in a country irrespective of where they are produced. It is like a sales tax except that a sales tax is levied on the entire value of the goods and services, while the destination-based tax is levied only on profits from their sale.

The United States of America has a fourth variant: it taxes profits made by American companies abroad only if they are transferred to the US, and gives a credit for tax paid in the country where they arose. So American companies have been avoiding transfer of profits to the US: they either keep the profits in the country where they are made, or set up a subsidiary in a tax haven - one which levies no tax or low tax on profits or their components - and transfer profits from subsidiaries in other countries to the subsidiary in the tax haven. According to Trump's sources, American companies have cash balances of $2.5 trillion abroad.

The Trump plan aims to make American companies bring this cash to the US, and to stop accumulating cash abroad. To do so, it will give them an incentive: it proposes to charge only 10 per cent tax on repatriated money. This tax will apply not only to current cash balances abroad, but to any further accumulation of balances.

Why do the companies keep their profits abroad? That is because the US corporation tax rate of 38.9 per cent is amongst three highest in the world. Puerto Rico - which is a state of the US - levies 39 per cent; the United Arab Emirates levies 55 per cent. A number of countries, including India, Brazil and Argentina, have rates between 33 and 35 per cent. Some tax havens, including Cyprus, Liechtenstein, Macao and Gibraltar, have rates between 10 and 15 per cent. The most common rates, levied by more than 80 countries, are between 15 and 25 per cent. The Trump plan envisages bringing down the corporation tax rate to 15 per cent. That would be unfair to unincorporated businesses, so it will tax their profits too at 15 per cent. And the rest? They will be taxed as persons at rates going up to 25 per cent, and get discounts on the tax rate of 5-10 per cent on dividends and capital gains. Is that not unfair? Trump has never let himself be worried about fairness. He has promised to remove "death tax" - estate duty levied on the value of assets left behind by rich men for their children.

If one business invests in another and receives dividends, they are taxed in the payer's hands before he hands them out. But if it gives a loan and receives interest, it is treated as an expense of the payer and he can debit it to his profit and loss account as a cost. So it saves tax to invest money as a fixed-interest loan than as equity. The discrimination could be easily removed by treating dividends as a cost or removing interest from costs. But no country does that, for the entire banking industry profits from the favour done to interest. Trump plans to impose a "reasonable" cap on charging of interest as cost.

There is one part of Trump's intentions that is not in the formal plan, namely to get rid of Indian IT workers and give the jobs to Americans. How he will do it has not been specified, but it could be easily done by denying visas to Indian IT workers. Work that currently flows from the US to Bangalore would rile Trump equally, but it is difficult to see what policy measure could stop it. He will try "moral" persuasion. Transfers from abroad bring about $60 billion a year into India; so do service exports from India. So the balance of payments is vulnerable to a Trump attack. There is no foolproof defence against it, but persuading American companies to come and work in India and employ Indians is worth trying. In general, our government should abolish restrictions on inward foreign direct investment and on entry of foreign workers of foreign companies.

The time has come to give substance to the prime minister's slogan, Make in India. Altogether, international trade has been shrinking, and so has India's trade; now is the time to attract foreigners to India - not just to be educated or medically treated, but to set up any activity that has an international market and can have a net earning of foreign exchange. I am in Colombo just now; every day I see Maldivians who have exiled themselves to green Sri Lanka, and Europeans enjoying a tropical winter. They could do so in India too.

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