[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
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