“Most countries, including the United States since the passage of 2017’s Tax Cuts and Jobs Act, use some version of a “territorial” system. Territoriality is a basic principle of good tax policy and means that governments don’t tax their taxpayers’ foreign-earned incomes. That money is instead taxed by the foreign jurisdictions where it is earned. Firms can choose where to do business based on what country has the best tax regime. This approach puts pressure on governments with punishing tax regimes to become less draconian.
High-tax nations don’t like this competition, which is why they’ve been itching for the past decade to undermine it with a global minimum tax. And while the U.S. government is set to benefit immensely from the new regime, U.S. companies with foreign subsidiaries and income will not.”