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Ed McClellan

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Clients rely on Ed McClellan's experienced counsel for their most technically sophisticated tax legislative challenges. Ed has over 35 years of experience in tax policy and technical tax analysis, having spent 16 years in private practice before serving as Tax Counsel on the U.S. Senate Finance Committee. A member of the Tax and the Public Policy practices, his practice focuses on federal tax legislation.

Ed advises clients across a wide range of industries on legislation relating to international taxation, domestic corporate taxation, corporate integration, redomiciliations, financial services, capital gains, dividend taxation, financial products, REITS, pass throughs, and accounting methods.

During his seven-year tenure with the Senate Finance Committee, Ed served as a lead tax counsel on the American Jobs Creation Act of 2004, the Jobs and Growth Tax Relief Reconciliation Act of 2003, the Job Creation and Worker Assistance Act of 2002, the FSC Repeal and Extraterritorial Income Exclusion Act of 2000, and the Tax Relief Act of 2001.

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In mid-May, the Biden Administration officially threw its support behind a minimum global corporate income tax rate of at least 15%.  The US proposal would be limited to the world’s 100 largest companies – those with revenues of over $20 billion.  The proposal would not depend on the company’s nationality (the US has made clear…

Vice President Biden campaigned on a number of tax proposals:

  • Raise the corporate rate from 21% to 28% “on day one”
  • Increase the Global Intangible Low Taxed Income rate from 10.5% to 21%
  • Create a new corporate alternative minimum rate of 15% on financial statement income over $100 million
  • Increase the top individual rate and

…

Procedural questions over when a budget resolution’s reconciliation instructions become stale have swirled for years.  There were three options:

  • the end of a fiscal year;
  • until the next budget resolution overtakes it (and next budget resolution could certainly affirmatively preserve it); or
  •  the end of a Congress. 

The huge news out of the Senate today …

On April 26, 2017, Treasury Secretary Steven Mnuchin and National Economic Council Director Gary Cohn introduced the Trump Administration’s tax reform proposal (the “Trump Proposal”) in a briefing. The proposal appears to borrow heavily from the tax reform plan put out by Mr. Trump during his presidential campaign with the significant exception that this reform…