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Corporate Tax Money, Mapped at Last: New Disclosures Show Big Overseas Payments and Ignite Scrutiny

Denise Lugo, Checkpoint News  Senior Editor

· 6 minute read

Denise Lugo, Checkpoint News  Senior Editor

· 6 minute read

Some of America’s biggest brands are finally showing where their tax money really goes — and in a number of cases, it isn’t going to Washington.

That new visibility is coming from the Financial Accounting Standards Board’s (FASB) updated accounting disclosure requirements (ASU No. 2023-09) that require companies to provide more detail in their annual reports about cash taxes paid and other tax metrics. For years, investors and transparency advocates argued that the standard public filings made it too hard to tell how much companies actually paid — and where.

“The new filings are quickly splitting into two different stories: one in ‘cash taxes paid’, and another in ‘rate reconciliation’,” said Thomas Georges, policy officer at FACT Coalition, a corporate tax and transparency advocacy group.

That detail is newly visible because FASB’s ASU 2023-09 (Topic 740) now requires companies to break out cash income taxes paid (net of refunds) by jurisdiction—including naming any country or state that accounts for 5% or more of total cash taxes paid—along with other enhanced income-tax disclosures. For most public business entities, the rule is effective for fiscal years beginning after December 15, 2024, meaning calendar-year companies are first reporting it in 2025 results filed in early 2026—which is why the new country-by-country-style detail is popping up in 10-Ks.

The First Wave of Filings Fuels “America-Last” Claims

Now the early results are fueling a fresh round of tax-code scrutiny. The FACT Coalition on February 6, 2026, said the first wave of filings shows a pattern it calls “America-last”: companies with major U.S. operations paying surprisingly little in U.S. federal income taxes while sending larger checks to foreign governments, including in places often associated with tax avoidance strategies.

Georges said the cash-tax breakdowns are already showing “companies paying substantially more tax to foreign governments than… the US federal government,” a pattern he said is turning up even among “iconic American brands.”

In aerospace and autos, the coalition points to filings it says show Boeing paying more than twice as much tax in Germany as in the U.S., and General Motors paying more income tax to Canada and Mexico than to the U.S. government.

Profit-Shifting Hotspots Show Up in Black and White

Some of the disclosures also spotlight countries long linked to profit shifting — a catchall term for strategies that move profits on paper to low-tax jurisdictions. Meta reported substantial cash tax payments to Ireland, the group said, a country that has played an outsized role in how some tech and pharmaceutical companies structure their global tax bills.

Singapore shows up too. FACT says GE Aerospace paid more tax in Singapore than it paid to the U.S. federal government in 2025, even though the group describes most of the company’s profits as domestic. It adds that some of the Singapore payments may reflect collections under the OECD-backed global minimum tax — a reminder that foreign minimum-tax regimes can sometimes bite harder than U.S. rules.

Georges said the rate-reconciliation details point to “continued widespread use of tax havens,” with “Singapore… Ireland… the Netherlands and Switzerland” among the places “showing up a lot.”

Where Companies Sell — and Where They Say They Earned the Profits

The new filings also make it easier to compare where companies make money and where they report profits. GE Vernova, a GE spinoff, made nearly half of its 2025 revenue in the U.S. but reported less than 3% of its pre-tax profits domestically, FACT said. The company reported that it reduced its overall tax rate through jurisdictions including Ireland, the Netherlands and Singapore, according to the coalition’s research.

PepsiCo showed a similar split, the coalition said: more than half of its 2025 net revenues were in the U.S., but less than 10% of pre-tax income was reported domestically. FACT cited major tax-rate reductions tied to Ireland, Singapore, Switzerland and Bermuda, and said Pepsi reported large cash tax payments to Ireland and to Russia, where it has maintained substantial operations despite Russia’s war in Ukraine.

Tesla as the Headline Example

FACT argues the starkest example is Tesla. The coalition said Tesla paid $28 million to the U.S. government in 2025 — about 27 times less than the $751 million it paid to China — and expected to owe no same-year federal income tax for 2025, despite reporting that most of its profit is domestic. The group also pointed to prior analysis by the Institute on Taxation and Economic Policy, which has long criticized Tesla’s low U.S. federal income tax payments.

A Big Caveat: Cash Taxes Can Swing for Non-Obvious Reasons

Tax specialists caution that “cash taxes paid” can swing year to year because of timing differences, audit settlements, and payments tied to earlier periods. But transparency advocates argue that when the same patterns recur across companies — especially when profits seem to pile up in low-tax jurisdictions — it raises hard questions about whether the U.S. tax code is collecting what lawmakers intended.

Georges argues the disclosures are, at minimum, a window into how policy choices land in practice — “how generous” he said “corporate tax cuts have been.”

The Policy Fight: GILTI, Subpart F, and Incentives to Book Income Abroad

At the center of that debate are U.S. rules such as Global Intangible Low-Taxed Income (GILTI), and Subpart F, designed to reduce the payoff from shifting profits offshore. FACT says those guardrails aren’t strong enough, leaving companies with incentives to keep routing profits through favorable jurisdictions.

Georges said he’s repeatedly seen companies disclose U.S. “anti-abuse” taxes, but not at levels that erase the upside: “never is the GILTI … or the Subpart F liability large enough to fully offset” the benefit tied to specific low-tax jurisdictions. “The savings,” he said, “seem to be larger” than what companies accrue under U.S. rules.

FACT policy director Zorka Milin said the international backdrop could raise the stakes. Under the OECD’s “pillar two” framework, she said, “U.S. companies” are “no longer subject to key parts” of the deal — which, in her view, “puts more pressure on the US rules” such as GILTI. The disclosures, she added, “indicate” there is “room to make them stricter,” calling the new reports “important evidence” of corporations “parking their profits in tax havens.”

More Jurisdiction-Level Data is Coming in 2026

More disclosures are coming. Later in 2026, FACT says, public country-by-country reporting rules in the European Union and Australia are expected to force additional multinationals — including Microsoft and Apple — to publish more jurisdiction-level information. For tax-policy watchers, that means the argument over corporate taxes is shifting from estimates and hunches to something far more concrete: numbers in black and white.

 

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