As the U.S. Senate is set to consider President Trump's domestic policy bill, non-U.S.-based multinational businesses and non-U.S. investors are preparing for wholesale changes to the U.S. international tax landscape,...more
On Friday, May 9, the House Ways and Means Committee released a portion of its draft tax legislation (the “House Draft Bill”) to amend the Internal Revenue Code of 1986 (the “Code”). The House Draft Bill is primarily...more
The House Committee of Ways and Means (the “House”) has been busy the last few days. Indeed, the House continues to mark up and work through potential revenue raisers (i.e., tax increases) to help pay for recent legislative...more
In this final blog post on the House Ways and Means Tax Bill, we address the international tax proposals in the Bill, JCX-43-21. The international tax proposals are fewer in number than the domestic and transfer tax...more
This chart compares the Biden Administration’s Fiscal Year 2022 Revenue Proposals (the Greenbook), to the tax proposals in the Build Back Better Act (BBBA) approved by the House Ways and Means Committee on September 15, 2021....more
• The Tax Cuts and Jobs Act (Tax Act), signed into law on Dec. 22, 2017, made significant changes to the manner in which U.S. corporate and individual taxpayers are taxed on income from international operations. • The Tax...more
Introduction - U.S. taxation of intellectual property has become astoundingly more complex after the Tax Cuts and Jobs Act. The new rules are so complex that the IRS and Treasury are still figuring out the details of how...more