GET INVOLVED



Email     Print

Thursday, June 17, 2010
5:30 PM EDT
Jeremy Weltmer

ATRF Analysis: International Tax Hikes in H.R. 4213

[ATRF analyses on all Obama Administration Proposals to “Reform the U.S. International Tax System”]

H.R. 4213, the “American Jobs and Closing Loopholes Act of 2010,” better known as the Extenders Bill, will most likely come up for a vote in the Senate before the end of the week. It includes a staggering $14 billion in international tax hikes. If this bill passes, the negative effects of these arbitrary and capricious changes will be borne by American shareholders, employees, and consumers.

Americans for Tax Reform Foundation is currently producing analyses of the eight tax hikes in the legislation:

Rules to prevent splitting foreign tax credits from generally the income to which they relate

Denial of foreign tax credit with respect to foreign income not subject to United States taxation by generally reason of covered asset acquisitions

Separate application of foreign tax credit limitation, etc., to items resourced under treaties

Limitation on the amount of foreign taxes deemed paid with respect to section 956 inclusions

Special rule with respect to certain redemptions by foreign subsidiaries

Modification of affiliation rules for purposes of rules allocating interest expense

Termination of special rules for interest and dividends received from persons meeting the 80-percent foreign business requirements

Source rules for income on guarantees

Posted by Jeremy Weltmer on Thursday, June 17, 2010 5:30 PM EDT
blog comments powered by Disqus

Americans for Tax Reform

  • 722 12th ST NW
  • Suite 400
  • Washington DC 20005
  • 202.785.0266 (P)
  • 202.785.0261 (F)

Quick Links

Connect

Join the ATR Email List

Designed and Developed by Braynard Group, Inc.
hidden