Archives: Tax Reform

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Framework for Tax Reform

This morning, the Unified Framework on Tax Reform was released by Republican members of the House Ways & Means Committee, Senate Finance Committee, and the Trump Administration.  Some high level summaries and observations follow. Individual Rates Doubles the standard deduction to $24,000 for a married couple filing jointly and $12,000 for a single individual, thus … Continue Reading

Trump Tax Reform Proposal

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 … Continue Reading

The President’s Long-Forgotten Power To Raise Tariffs

President-elect Trump’s expressed interest in possibly raising tariffs on imported goods has prompted considerable effort in trying to understand the scope of Presidential authority to raise tariffs. While the Congress has primary authority to set tariffs and the U.S. has made extensive international commitments to not raise tariffs, President-elect Trump will have a degree of … Continue Reading

Tax Reform in the Next Congress

It is clear that the next Congress and President-elect Trump very likely will to try to do corporate tax reform — particularly international tax reform. Among the reasons this is the case is that there is an emerging consensus among both parties from a policy perspective that improving the business tax code could make America … Continue Reading

A New Miscellaneous Tariff-Cutting Process Takes Shape

In a notice published in Friday’s Federal Register, the U.S. International Trade Commission (ITC or Commission) has issued interim rules implementing the new miscellaneous tariff bill process mandated by Congress in the American Manufacturing Competitiveness Act of 2016.  The rules create a new pathway for U.S. manufacturers to seek temporary suspension or reduction of tariffs … Continue Reading

IRS Steps into Fray on Political Activities

The Internal Revenue Service (IRS) recently issued two private letter rulings (PLRs) that may be interesting for tax-exempt organizations that engage in political activity. In the first ruling, the IRS held that a company could not deduct payments made to charity under a PAC matching contribution program as an “ordinary and necessary business expense.”  While … Continue Reading

As We Were Saying, Tax Reform is Dead

Back in our January post, “Tax Reform is Dead!  Long Live Tax Reform!” we predicted that the President’s approach to tax reform as outlined in his State of the Union speech was so fundamentally incompatible with the approach of congressional Republicans that comprehensive tax reform legislation was highly unlikely to make meaningful headway during this … Continue Reading

European Tax Investigations

In June, the European Commission (“EC”) announced the opening of three investigations into tax rulings in Ireland, Luxembourg and the Netherlands and, in particular, into tax rulings applied by Ireland to Apple, by Luxembourg to Fiat Finance and, last, by the Netherlands to Starbucks. In October 2014, the EC announced the opening of a fourth … Continue Reading

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 inversions, including so-called “spinversions” and … Continue Reading

Tax Fairness for Renewable Energy

Congress has a great opportunity to amend the tax code in a way which will benefit the environment, promote American jobs, and foster diversity in our energy sources. It can achieve these results by enacting the Master Limited Partnerships Parity Act. Since the early 1980’s, oil and gas producers have been permitted to use Master … Continue Reading

Important Tax Issues in Congress

Now that comprehensive tax reform is dead in this Congress, the battle has shifted to tax extenders—the fifty odd temporary provisions of the tax code, most of which expired December 31, 2013.  It is anticipated that, as in past years, most will be reauthorized. The Administration fired a broadside on May 6, however, threatening to … Continue Reading
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