Two quite separate email conversations drew me to the subject of minimum corporation tax rates this weekend.

One was with old friend Krishen Mehta, a former PWC partner in the USA, who drew my attention  to a BNA Bloomberg article that noted that:

The U.S. business community has lost the global public relations battle on international tax planning–and should consider whether a proposed global minimum tax would be better for their interests than continuing with the status quo, a top Treasury Department official said.

Robert Stack, deputy assistant secretary for international tax affairs, said global non-governmental organizations have “eaten the lunch” of U.S. multinationals on setting and influencing the global political agenda. 

“It isn't even a close call,” Stack said. “In fact, they haven't only eaten the lunch of the business community, they've eaten their breakfast, lunch and dinner.”

Continued media coverage about alleged tax abuse, increasingly aggressive actions from tax administrations and the general terms of debate about standard international tax practices show that multinationals have lost control of the “narrative,” Stack said.

He is right of course. And his argument was that the proposed global minimum tax – which would tax the worldwide profits of U.S. corporations at 19 percent - would discourage companies from stripping earnings to low-tax jurisdictions, and thus dampen political controversies about stateless income has some merit.

But it so happened that the idea of minimum taxes also cropped up in another conversation with Alex Cobham of the Tax Justice Network and dragged my mind back to a proposal for just such a minimum tax that I wrote in 2008 at the time TJN was trying to engage with the very NGOs that Robert Stack now admits have joined with TJN to win this issue, hands down. The proposal was never published: we concluded it was too radical at the time, and so this document never saw the light of day.

Some aspects of the proposal now feel dated. The fact that we never thought there would be country-by-country reporting on public record at that time gives rise to an obvious omission that would not be repeated now.

But what I did find surprising was that a variation on a proposal that I wrote less than a decade ago that was considered too radical at the time to be campaigned upon is now being seriously put forward by the US Treasury. We have definitely won the argument.

Comment on my 2008 document, the essence of which is as I wrote it at the time with some now superfluous details eliminated in the version published here, would be of interest. And it's still there to be campaigned on if anyone wants to work with me to update it, because we can be pretty sure Obama will not be delivering his version.