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.
- by Patrick DriessenIn 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.
- by Richard RubinWhile 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.
- by Andrew GoodallThe 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.
- by Amy S. Elliott & Lee A. SheppardThe 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.
- by Alison BennettThe 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.
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 effectiby Rick MitchellNew 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.
- by Alison BennettInsurance 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.
- by Kevin A. Bellby Kevin A. BellFinal 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.
- by Ryan FinleyOn 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.