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The U.S. Tax Code: Love It, Leave It, Or Reform It!

On July 22, 2014, the Senate Finance Committee held a hearing titled, “The U.S. Tax Code: Love It, Leave It, or Reform It!” The general topic of the hearing was international taxation, with a sharp focus on recent and...more

Editorial: Corporate Inversions No Signs Of Slowing Down

In a corporate inversion, a U.S. corporation — typically the parent of an affiliated group — becomes a wholly owned subsidiary of a foreign corporation through a merger into the foreign corporation's U.S. subsidiary or...more

Wyden’s Previous Proposals Could Signal Tax Reform Priorities

Senator Ron Wyden (D-OR) has been a strong advocate for comprehensive tax reform since he joined the Senate Finance Committee in 2005. During his tenure on the Committee, he has introduced a series of comprehensive tax reform...more

The Inversion Craze: Will Today's Routine Tax Planning Be Retroactively Outlawed?

Alongside the more typical summer fare, such as coverage of the best beach reading and the latest action movie blockbuster, this summer the media have been abuzz with seemingly daily reports on the latest so-called...more

Congress Returns from July 4th Recess - What to Expect in the Coming Months

Although the 113th Congress continues to see a dearth of legislation seeing final approval, over the past six months, Congress has managed to finalize Fiscal Year 2014 appropriations; address the Sustainable Growth Rate...more

Corporate Inversions Showing No Signs of Slowing Down

In a corporate inversion, a U.S. corporation (typically the parent of an affiliated group) becomes a wholly owned subsidiary of a foreign corporation (through a merger into the foreign corporation’s U.S. subsidiary) or...more

Is Your Company Prepared For The Potential Impacts Of The Stop Corporate Inversions Act of 2014

As Congress Seeks Additional Funding, Inversion Proposal Emerges - Throughout the past several weeks, Pfizer’s attempt to acquire AstraZeneca has garnered significant congressional and media attention. Pfizer, a U.S....more

House Approves Bill to Make R&D Tax Credit Permanent

On May 9, the U.S. House of Representatives passed the American Research Competitiveness Act of 2014, which would make permanent the expired research and development (R&D) tax credit. The bill, H.R. 4438, passed...more

Washington Insight - May 2014

In This Issue: - Politics Drives the Agenda in Run-Up to the Midterms - An Insider's View: President Obama's Foreign Policy - The Anti-Energy Tax Incentives Caucus of the GOP - Trade Agenda Stagnant, For...more

Information Letter: Update on legislative developments in Russia. Governmental De-offshoring initiatives. Proposed new CFC and...

When it was first revealed by President Vladimir Putin a few years ago that the offshore-backed modus operandi for the Russian economy could no longer be tolerated, very few could have predicted that the Government would be...more

Energy And Environment Update

In This Issue: Energy and Climate Debate; Congress; Administration; Department of Commerce; Department of Energy; Environmental Protection Agency; Federal Energy Regulatory Commission; International; States; and...more

The Elevator Speech Overview

The House and Senate were both in session this week, the President was traveling overseas. President Obama announced his backing for an overhaul of the NSA bulk phone data collection program, a plan that differs from the...more

Camp unveils major tax reform plan

Yesterday, House Ways and Means Committee Chairman Dave Camp (R-Michigan) unveiled his comprehensive tax reform proposal. Released as draft legislation, the Camp proposal calls for the most fundamental reform of the tax code...more

Senate Hearing Takes Aim on Offshore Tax Evasion

Today, February 26, 2014, the Senate Permanent Subcommittee on Investigations will hold a hearing on offshore tax evasion titled “Offshore Tax Evasion: The Effort to Collect Unpaid Taxes on Billions in Hidden Offshore...more

Energy And Environment Update -- February 18, 2014

In This Issue: Energy and Climate Debate; Congress; Administration; Department of Energy; Department of State; Environmental Protection Agency; Government Accountability Office; International; States; and...more

Domestic Anti-Treaty-Shopping Proposals and Further Consultation Announced in Canada's Federal Budget 2014

In the Canadian Federal Budget released on February 11, 2014, the Department of Finance signaled its intention to enact a domestic treaty-shopping rule, generally allowing the Canada Revenue Agency (CRA) to deny treaty...more

2014: Turbulent Waters Ahead in Tax Policy

Although the prospect for comprehensive tax reform this year is dimming, debate on tax policy issues will continue to be prominent on Capitol Hill. Between election year dynamics, changes in committee leadership, the tax...more

Implications for Private Equity Funds of Canada’s Budget 2014 Proposed Anti-Treaty-Shopping Measures

This Update concerns a measure proposed in Canada’s federal budget for 2014, tabled by the Minister of Finance on February 11, 2014 (Budget 2014), relating to treaty shopping that may affect private equity (PE) funds...more

Energy And Environment Update -- January 29, 2014

In This Issue: Energy and Climate Debate; Congress; Administration; Department of Commerce; Department of Energy; Department of Transportation; Environmental Protection Agency; Federal Energy Regulatory Commission;...more

Washington Insight - January 2014

In This Issue: - Legislation to Renew Fast-Track Consideration for Trade Agreements Introduced - Congress Passes FY 2014 Omnibus Appropriations Bill - An Insider's View: Obama's Mid-Term Blues - What's in...more

"US Corporate Tax Reform: Stuck in Neutral"

Three significant international tax reform proposals in the United States have been released in the past three years: the International Tax Reform Discussion Draft released by House Ways & Means Committee Chairman Dave Camp...more

Senate Finance Committee Chairman Releases Tax Reform Staff Discussion Drafts – More Expected

From November 19 through 22, 2013, Senator Max Baucus, Chairman of the Senate Finance Committee (the "Committee"), released three staff discussion drafts that propose sweeping changes to the federal rules regarding...more

Senate Finance Committee Chairman Baucus Releases Staff Discussion Draft to Substantially Reform the U.S. International Tax System

Last week U.S. Senate Finance Committee Chairman Max Baucus (D-Montana) released a staff discussion draft (the “Discussion Draft”) of proposals that, if enacted, would dramatically change the U.S. international tax system....more

Chairman Baucus Issues a Discussion Draft on Tax Reform

Chairman Max Baucus has issued a discussion draft that offers some interesting and provocative proposals on corporate international tax reform. Designed to “reform international tax rules to spark economic growth, create...more

"Senate Finance Chair Proposes International Business Tax Reform"

On November 19, 2013, Sen. Max Baucus (D-Mont.), Chairman of the Senate Finance Committee, released a Staff Discussion Draft on International Business Tax Reform. The changes proposed in the discussion draft are far-reaching...more

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