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Category Archives: Tax

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Border Adjustability Tax in Peril?

The future of the Border Adjustment Tax (BAT) proposal, a critical element of the House Republican tax reform plan, is in doubt after signs of Republican opposition in the Senate emerged last week. Senator David Perdue (R-GA) became the most prominent Republican to overtly criticize the BAT, expressed in a Dear Colleague letter to his

New Treasury Notice Squeezes the Juice From Some Corporate Inversions – How Are You Impacted by the New Rules?

In response to a record number of pending “inversion” transactions and the perceived potential loss of tax revenue, the U.S. Treasury Department, on September 22, 2014, issued Notice 2014-52, announcing and detailing to-be-issued regulations intended to (i) make it more difficult to accomplish an inversion, and (ii) reduce the perceived tax advantages of doing so with respect to the untaxed earnings of foreign subsidiaries.

U.S. Tax Reform Update: House Ways and Means Chairman Tax Reform Discussion Draft – Proposals That Impact Colleges and Universities

The building blocks for what could eventually form the base of U.S. tax reform include dramatic proposals that will impact universities and colleges. The 979-page “Tax Reform Act of 2014” discussion draft introduced by House Ways and Means Chairman Dave Camp (R-MI)in March 2014 is a comprehensive reform package that would reduce U.S. corporate and

U.S. Tax Reform Update: House ways and means Chairman Tax Reform discussion draft, Obama budget proposals provide new building blocks for eventual U.S. Tax Reform:

The last two weeks have seen significant developments in building the blocks for what could eventually form the base of U.S. tax reform. Most significant is the 979-page “Tax Reform Act of 2014” discussion draft from House Ways and Means Chairman Dave Camp (R-MI) — a sweeping, comprehensive reform package that would reduce U.S. corporate

U.S. Tax Reform Update: Senate Finance Chairman Baucus issues significant reform proposals related to depreciation and international tax :

Last week saw important developments related to U.S. tax reform, with Senate Finance Committee Chairman Max Baucus issuing tax reform drafts proposing significant changes in several key areas of tax law. These proposals break new ground in the U.S. tax reform effort as they suggest dramatic changes in cost recovery (depreciation) and accounting, as well as

Congressional tax reform effort accelerates: Senate Finance Committee leaders call for “clean slate” and ask for proposals by July 26

The tax reform effort in the U.S. Congress has accelerated this month, with Senate Finance Committee Chairman Max Baucus and Ranking Member Orrin Hatch together issuing a Dear Colleague letter to fellow Senators, asking for their help in crafting a tax reform bill. The letter announced the committee leaders’ intention to mark-up a tax reform

Congressional tax reformers propose far-reaching tax changes for derivatives and other financial products

House Ways and Means Committee Chairman Dave Camp (R-Mich.) has proposed to tax derivatives on an annual mark-to-market basis with ordinary gain or loss treatment. This far-reaching proposal is the centerpiece of a series of tax changes for financial products set forth in a discussion draft released on January 24 as part of Chairman Camp’s