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
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Michael Caballero
Michael Caballero is a partner in the Washington office and a vice chair of the Tax Practice Group. His practice focuses on international tax matters, including structural and transactional tax planning, tax controversy, and tax policy work.
Michael previously served as International Tax Counsel in the U.S. Treasury Department’s Office of Tax Policy. While at the Treasury Department, he participated in the development of legislation, regulations, and administrative guidance concerning all aspects of international tax matters; oversaw the U.S. tax treaty program; and coordinated the representation of the United States in various international fora, including the Organisation for Economic Co-operation and Development (OECD).
Michael previously served in the Office of International Tax Counsel for almost six years as an Attorney Advisor and Associate International Tax Counsel with responsibility for legislative matters and administrative guidance regarding the foreign tax credit, cross-border M&A, inversions, international partnerships, FIRPTA, and PFICs.
Prior to his most recent time at the Treasury Department, Michael practiced as a tax partner at two global law firms.
Inversion Transactions Addressed in Treasury Notice
On Monday, September 22nd, the U.S. Department of the Treasury and the Internal Revenue Service (IRS) published Notice 2014-52 (the “Notice”) announcing their intention to issue regulations that would address corporate inversion transactions. If issued in the form described in the Notice, the regulations would prevent certain narrow categories of …
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