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
After the UK Brexit referendum of 23 June the implications on the political, economic and legal relations between the UK and the EU have been discussed from many angles. But what about one of the main pillars for the successful integration of the European Single Market: State aid law? Does the end of EU membership
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.
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
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
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
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
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