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  • The key to stopping inversions is tax reform, not political rhetoric

    by Brandon Arnold (Journal Sentinel)

    Politicians continue to rail against corporate inversions at every opportunity. Presidential candidates repeatedly have called for a government crackdown to prevent businesses from moving overseas. Unfortunately, most of their populist rhetoric misses the mark.

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    By Arnold, Brandon , posted on Tuesday June 7, 2016
  • Loss Symmetry for Start-Ups With an Anti-Inversion Chaser

    by Patrick Driessen
    In this article, Driessen suggests that the typical inversion script might be sidestepped by allowing new corporations to temporarily receive immediate cash payments from the U.S. government in lieu of carrying forward net operating losses -- an election of early refundability that would require companies to permit the Treasury secretary to veto any potential future inversion.
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    By Driessen, Patrick, posted on Thursday June 30, 2016
  • U.K. Tax Code Could Entice Companies

    by Richard Rubin
    While some companies consider moving operations from the United Kingdom after its expected exit from the European Union, the U.K. could use its tax code to entice businesses.
    The U.K. outside the EU would be liberated of the bloc's coordinated tax rules, giving the country an opportunity to cut taxes for companies, grant more financial aid to ailing firms and dangle breaks to attract corporations.
    To read more go here
    By Rubin, Richard, posted on Wednesday June 29, 2016
  • U.K. Lawmakers Approve Corporation Tax Cut

    by Andrew Goodall
    The U.K.'s low corporation tax rate attracts jobs and investment, and it would be a grave mistake to cancel a further cut to 17 percent planned for 2020, Financial Secretary to the Treasury David Gauke warned members of Parliament before they approved the cut by a vote of 308 to 255.
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    By Goodall, Andrew, posted on Thursday June 30, 2016
  • D.C. and New York Bars Submit Comments on Debt-Equity Regs

    by Amy S. Elliott & Lee A. Sheppard
    The District of Columbia Bar Taxation Section and the New York State Bar Association Tax Section both submitted comments on the proposed debt or equity regulations June 29, urging Treasury not to finalize the recast rules in prop. reg. section 1.385-3.
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    By Elliott, Amy S. & Lee A. Sheppard, posted on Thursday June 30, 2016
  • Throw Out Loan Recasts Under Debt-Equity Rules: NYSBA Group

    Bloomberg

    by Alison Bennett
    The government shouldn't go forward with rules that allow entire loans to be recast as equity in an attempt to stop earnings stripping, the New York State Bar Association Tax Section said in nearly 200 pages of comments to the government.
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    By Bennett, Alison, posted on Wednesday June 29, 2016
  • New OECD guidance on country-by-country reporting of multinational companies' tax and profits tackles thorny transition issues that arise when jurisdictions' reporting regimes have different effecti

    Bloomberg

    by Rick Mitchell
    New OECD guidance on country-by-country reporting of multinational companies' tax and profits tackles thorny “transition issues” that arise when jurisdictions' reporting regimes have different effective dates.
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    By Mitchell, Rick, posted on Wednesday June 29, 2016
  • Reinsurance Group to Meet With Treasury on Debt-Equity Rules

    by Alison Bennett
    Insurance companies and reinsurers would suffer a harsh burden and should be exempt from controversial new rules intended to combat earnings stripping, industry representatives are expected to tell the IRS and Treasury Department in a June 30 meeting.
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    By Bennett, Alison, posted on Wednesday June 29, 2016
  • Country-by-Country Rules Final; More IRS Guidance to Come

    by Kevin A. Bell

    Bloomberg

    by Kevin A. Bell
    Final rules on country-by-country reporting contain few changes from regulations proposed in December, but the IRS promises further guidance on a mechanism to allow voluntary filings for companies required to comply with both the U.S. rules and those in a foreign country with an earlier effective date.
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    By Bell, Kevin A., posted on Wednesday June 29, 2016
  • CbC Regs Finalized as OECD Issues Voluntary Filing Guidance

    by Ryan Finley
    On the same day Treasury and the IRS released final country-by-country reporting (CbC) regulations, the OECD issued guidance recommending that other countries accept for years beginning on January 1 reports filed voluntarily in the United States and in other countries that do not require reports.
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    By Finley, Ryan, posted on Thursday June 30, 2016