The Resource The practical effects of the Obama international tax proposals

The practical effects of the Obama international tax proposals

Label
The practical effects of the Obama international tax proposals
Title
The practical effects of the Obama international tax proposals
Creator
Subject
Language
eng
Summary
This article discusses the Obama administration's international tax proposals, focusing on the following administration proposals representing a change in tax policy, not an end to tax abuse: (1) the repeal of the check-the-box regulations (with an extension for one year of the look-through rule in section 954(c)(6)); (2) the reallocation and deferral of U.S.-source deductions until foreign-source income is repatriated; and (3) the aggregation of foreign tax credit (FTC) pools into one blended rate for purposes of the section 902 deemed-paid FTC. This article also discusses several proposals that are targeted at stopping perceived inequality in the tax system: (4) FTC matching with income recognition; (5) the repatriation of earnings via foreign tax-free reorganizations; (6) earnings stripping limitations on expatriated companies; and (7) the imposition of withholding tax on equity swaps. These proposals are aimed at reversing tax results that arise from the application of current tax law, and there may be policy reasons that justify these proposals
Citation source
In: Tax notes international. - Falls Church. - Vol. 55 (2009),
http://library.link/vocab/creatorName
  • Reardon, J
  • Ohrn, J
Geographic coverage
North America
Language note
English
http://library.link/vocab/subjectName
  • tax policy
  • check-the-box regulations
  • foreign tax credit
  • repatriation
  • earnings stripping
Label
The practical effects of the Obama international tax proposals
Instantiates
Publication
Label
The practical effects of the Obama international tax proposals
Publication

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