Mission & GOALS

Founded in 1992, the International Tax Policy Forum (ITPF) sponsors nonpartisan academic research and conferences to promote an informed dialogue on international tax issues. Currently, ITPF's membership includes more than 40 major, U.S.-based multinational companies. Contact Us


Board of Advisors

Alan J. Auerbach
Mihir A. Desai
Michael Devereux
Michael J. Graetz
Michelle Hanlon
James R. Hines, Jr., Research Director
Matthew Slaughter

Glen Hubbard

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Latest News

News Analysis: U.S. Treasury Doubles Down on Inbound Planning

by Mindy Herzfeld (Tax Notes)

By carving out debt of foreign issuers from the final section 385 regulations, Treasury effectively mooted a lot of the criticism of its proposed regulations. However, by keeping the funding rule without relaxing it in any meaningful way, the government made sure the final rules strongly targeted inbound planning activities of foreign multinationals.

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What Apple Teaches About How Not to Reform Corporate Taxes

by Gary Kalman (Tax Notes)

In this article, Kalman uses the recent Apple tax ruling by the European Commission to identify problems with proposals for a territorial tax system in the United States. He argues that policymakers should instead focus on ending deferral, requiring public country-by-country reporting, and adopting provisions of the Stop Tax Haven Abuse Act.

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Treasury Sets High Bar for Ability to Repay in Debt-Equity Regs

by Amy S. Elliott (Tax Notes)

One of the four documentation requirements in the final section 385 debt-equity regs (T.D. 9790 2016 TNT 199-5: IRS Final Regulations) is that the documentation establish that the issuer's financial position supports a reasonable expectation of its ability to repay the debt. How much debt does a taxpayer need the wherewithal to repay? According to Treasury, possibly all of it.

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