Tax Reform

Before the elections, pollsters were confident that the United States faced another four years of divided government. With Republicans in control of both houses in Congress and the White House, the air is alive with talks of tax reform. Could 2017 be the year of tax reform? It's quite possible...
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IRC Section 385

When the IRS and the U.S. Treasury Department on April 4, 2016, issued proposed regulations to address earnings stripping under IRC section 385, tax practitioners began attempting to understand the potential ramifications. It seemed that Treasury was using the proposed regulations to curb the use of inversions by recharacterizing certain related-party financings as equity.
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Diverted Profits Tax

The diverted profits tax is intended to deter large groups (as defined by the EU) from diverting profits by engaging in transfer pricing without economic substance or by avoiding the creation of a U.K. permanent establishment that would make a foreign company subject to U.K. corporation tax.
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Destination-Based Cash Flow Tax

In June 2016, as part of the "A Better Way" initiative from U.S. House Speaker Paul D. Ryan, R-Wis., a blueprint for tax reform was released. It was the last of six policy planks requested by Ryan. One of the major reforms included in the blueprint proposal was the introduction of a destination-based cash flow tax.
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Tax Notes Select

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Base Erosion and Profit Shifting (BEPS)

In 2014 the OECD embarked on a high-profile project to reform international tax rules with a focus on base erosion and profit shifting. The project was a response to growing public and political outcry against a system that allows multinationals to generate significant revenue with a low- or zero-tax burden in a particular jurisdiction.

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Destination-Based Cash Flow Tax

In June 2016, as part of the "A Better Way" initiative from U.S. House Speaker Paul D. Ryan, R-Wis., a blueprint for tax reform was released. It was the last of six policy planks requested by Ryan. One of the major reforms included in the blueprint proposal was the introduction of a destination-based cash flow tax.

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Diverted Profits Tax

The diverted profits tax is intended to deter large groups (as defined by the EU) from diverting profits by engaging in transfer pricing without economic substance or by avoiding the creation of a U.K. permanent establishment that would make a foreign company subject to U.K. corporation tax.

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IRC Section 385

When the IRS and the U.S. Treasury Department on April 4, 2016, issued proposed regulations to address earnings stripping under IRC section 385, tax practitioners began attempting to understand the potential ramifications. It seemed that Treasury was using the proposed regulations to curb the use of inversions by recharacterizing certain related-party financings as equity.

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President Donald Trump

Tax reform could be on President Trump's 100-day agenda. Among the ideas in Trump's tax plan are moves to reduce marginal tax rates, increase standard deductions, limit or repeal tax expenditures, repeal individual and corporate alternative minimum taxes, and repeal the estate and gift taxes.

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Tax Reform

Before the elections, pollsters were confident that the United States faced another four years of divided government. With Republicans in control of both houses in Congress and the White House, the air is alive with talks of tax reform. Could 2017 be the year of tax reform? It's quite possible...

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Treaties - Permanent Establishment

A multinational corporation doing business in foreign countries is taxable in those countries in which it conducts business only if it has a permanent establishment in those countries. A corporation can typically establish PE in a foreign country by either having a fixed place of business within the taxing country or operating in the taxing country through a dependent agent...

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Treaties - U.S. Model Tax Treaty

The OECD model tax treaty is generally used as a starting point for treaty negotiations by OECD member countries and other countries with more advanced economies. Developing countries typically prefer to use the model treaty developed by the U.N. because it allocates more taxing rights to source countries (which tend to be developing countries)...

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Unclaimed Property

A so-called quiet source of revenue, unclaimed property can provide states with a significant amount of money. Given budget constraints in recent years, states have been aggressively pursuing unclaimed property. And there is a lot to pursue.

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