Capital Thinking Blog

 
07.21.2014

Tax and Retirement

LEGISLATIVE ACTIVITY

House Passes hIGHWAY fUNDING bILL, sENATE Prepares TO vOTE oN Legislation

Last week, the House voted 367-55 to pass H.R. 5021, the Highway and Transportation Funding Act of 2014. The bill would patch and reauthorize the Highway Trust Fund (HTF) through May 2015 by using transfers from the General Fund and the Leaking Underground Storage Tank Trust Fund (LUST Fund). To offset the cost of the General Fund transfer, the bill calls for pension smoothing and customs fees.  As noted in previous coverage, while the Senate Finance Committee’s version of HTF funding legislation includes many of the same provisions as the House bill, it also incorporates additional revenue-raising compliance measures.

Moving forward, Senate Majority Leader Harry Reid (D-NV) has announced he will likely call for votes on three separate proposals: (1) the House-passed bill; (2) the Senate Finance Committee proposal; and (3) a plan from Senator Barbara Boxer (D-CA), which would extend current policy through December 2014. It is expected that the Senate will simply pass the House version of the bill, given that Congress must enact legislation before the August recess to prevent a slowing in HTF payments to the States.

sENATE Finance TO FOCUS ON iNVERSIONS

On July 15, Treasury Secretary Jack Lew sent a letter to leaders of the Congressional tax-writing committees calling for a “new sense of economic patriotism” and urging lawmakers to take action to curb corporate tax inversions. Further, the Obama Administration has suggested that any such legislation be retroactive to May 2014.

Last week, after noting that “this inversion loophole must be plugged,” Senate Finance Committee Chairman Ron Wyden (D-OR) announced that his committee will hold a hearing on Tuesday, July 22, to address the issue. However, not all lawmakers are in favor of standalone inversion legislation. For example, Senate Finance Committee Ranking Member Orrin Hatch (R-UT) noted “there may be steps Congress can take, short of comprehensive tax reform, to address corporate inversions, and related issues….I’m certain we can find alternatives that could easily be enacted and are less punitive and restrictive to businesses than those outlined” by the Obama Administration. On the House side, Ways and Means Committee Chair Dave Camp (R-MI) has suggested that anti-inversion legislation is not the solution, instead focusing his efforts on comprehensive reform.

THIS WEEK’S HEARINGS:

  • Tuesday, July 22: The Senate Finance Committee will hold a hearing titled “The U.S. Tax Code: Love It, Leave It, or Reform It.”
  • Tuesday, July 22: The Senate Homeland Security and Governmental Affairs Permanent Subcommittee on Investigations will hold a hearing titled “Abuse of Structured Financial Products: Misusing Basket Options to Avoid Taxes and Leverage Limits.”
  • Wednesday, July 23: The House Ways and Means Subcommittee on Oversight will hold a hearing titled “Integrity of the Affordable Care Act’s Premium Tax Credit.”

Regulatory ACTIVITY

irs iSSUES fINAL rULES on mIXED sTRADDLES

On July 17, the Internal Revenue Service (IRS) issued final regulations (T.D. 9678), which provide guidance on how a taxpayer can account for unrealized gain or loss on a position held before the taxpayer establishes a mixed straddle using straddle-by-straddle identification. The guidance is applicable to mixed straddles under tax code Section 1092, which are identified after August 18, 2014.

Brandon Roman
Brandon Román advises domestic and international clients on a range of legal, legislative, and regulatory issues.
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Erin McGrain represents international and domestic clients on a range of legislative, administrative and policy matters.
07.14.2014

Tax and Retirement

LEGISLATIVE ACTIVITY

House to vote on HIGHWAY FUNDING BILL, other tax measures

This week, the House is expected to vote on H.R. 5021, the Highway and Transportation Funding Act of 2014.  The bill, which was reported out of the Ways and Means Committee along party lines on July 10, would patch the Highway Trust Fund (HTF) through transfers from the General Fund and the Leaking Underground Storage Tank Trust Fund. To offset the cost of the General Fund transfer, the bill calls for pension smoothing and customs fees. The bill not only provides a short-term patch for the HTF, but would also extend the HTF’s authorization through May 2015. The Senate Finance Committee also marked up its version of HTF funding legislation on July 10. While the Senate version includes many of the same provisions as the House bill, it also includes additional revenue-raising compliance measures aimed mostly at tax evasion, not found in the House version. As such, both measures will need to be reconciled before any legislation is enacted by Congress. In order to prevent a slowing in HTF payments to the States, Congress must enact legislation before the August recess.

Additionally, this week, the House will also consider five charitable tax provisions, which were marked up by the Ways and Means Committee on May 29. The provisions include: (1) The Fighting Hunger Incentive Act of 2014 (H.R. 4719), which would permanently extend the deduction for charitable contributions of food inventory; (2) The Conservation Easement Incentive Act of 2014 (H.R. 2807), which would permanently extend the deduction for charitable contributions of real property interests by individuals and corporations for conservation purposes; (3) The Permanent IRA Charitable Contribution Act of 2014 (H.R. 4619), which would make permanent the rule allowing some tax-free distributions from IRAs for charitable purposes; (4) H.R. 3134, which would allow individuals’ charitable contributions made between the end of the tax year and the tax return due date to be treated as being made during the tax year; and (5) H.R. 4691, which would modify the rate for excise tax on the investment income of private foundations. The House, led by Ways and Means Committee Chairman Dave Camp (R-MI), remains committed to going “policy by policy” to determine which extenders should be made permanent, rather than pursuing the short-term, across-the-board solution pending in the Senate. On the Senate side, the EXPIRE Act (S. 2260), which would provide a two-year extension for certain tax extenders that expired on January 1, is stalled as a result of Republican objections over the amendment process.

Separately, the House will also consider the Permanent Internet Tax Freedom Act (H.R. 3086).

Brandon Roman
Brandon Román advises domestic and international clients on a range of legal, legislative, and regulatory issues.
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Erin McGrain represents international and domestic clients on a range of legislative, administrative and policy matters.
06.23.2014

Tax and Retirement

LEGISLATIVE ACTIVITY

SENATE FINANCE COMMITTEE Aims to MARKUP HIGHWAY FUNDING BILL

While not yet noticed, the Senate Finance Committee is expected to markup a short-term highway funding bill before the week-long July 4 holiday recess; however, it is possible that the markup will slip until Congress returns the week of July 7. While disagreements remain over how to fund the Highway Trust Fund (HTF) through the end of the calendar year, with the nearly $8 billion it will require, it appears that both Senate Finance Committee Chairman Ron Wyden (D-OR) and Ranking Member Orrin Hatch (R-UT) would prefer to offset the funding rather than use a non-offset general fund transfer. Specifically, Chairman Wyden has suggested funding the HTF through additional transportation-related tax revenue, while House Ways and Means Committee Chairman Dave Camp (R-MI) has noted that the Committee is “having discussions about a package of pay-fors that would fill the gap for some number of months.” The Ways and Means Committee is not expected to markup such legislation until after the July 4 holiday recess.  Additionally, while Chairman Wyden would prefer to fund the HTF through the end of 2014, both House and Senate Republicans are “going to try to get as long of an extension of the Highway Trust Fund as [they] can.”  Given that the HTF is set to run out of money this summer, a patch of some sort is necessary.

With an eye toward providing longer-term funding for the HTF, Senators Christopher Murphy (D-CT) and Bob Corker (R-TN) on June 18 introduced a bill calling for a gas tax increase. Specifically, the proposal would increase the federal gasoline and diesel fuel excise taxes by 12 cents per gallon over the next two years and index them to inflation, while cutting taxes by the same amount to offset the increase.   Additionally, as mentioned in previous coverage, Senate Majority Leader Harry Reid (D-NV) and Senator Rand Paul (R-KY) are working on legislation that would allow corporations to repatriate foreign earnings at lower rates and use this revenue as a long-term source of funding for improvements to transportation infrastructure. Notably, while many would like to pass a long-term funding bill, the pressure for greater offsets will likely serve as a barrier to timely passage of any such legislation.

THIS WEEK’S HEARINGS:

  • Tuesday, June 24: The Senate Finance Committee will hold a hearing titled, “Less Student Debt from the Start: What Role Should the Tax System Play?”
  • Wednesday, June 25:  The Senate Finance Committee will hold a hearing to consider the nominations of D. Nathan Sheets, of Maryland, to be an Under Secretary of the Treasury, vice Lael Brainard, resigned; Ramin Toloui, of Iowa, to be a Deputy Under Secretary of the Treasury, vice Charles Collyns, resigned; and Maria Cancian, of Wisconsin, to be Assistant Secretary for Family Support, Department of Health and Human Services, vice Carmen R. Nazario.

Regulatory ACTIVITY

IRS Updates FAQs and Form instructions, will issue more technical corrections

On June 19, the Internal Revenue Service (IRS) released an updated list of frequently asked questions (FAQs) on its downloadable and searchable list of foreign financial institutions (FFIs) that have registered under the Foreign Account Tax Compliance Act (FATCA). Specifically, the IRS has updated the FAQs with information about the registration deadline and XML/CSV files.

On June 24, the IRS will hold a hearing to discuss temporary regulations, which set forth rules related to information reporting by FFIs with respect to U.S. accounts and withholding on certain payments to FFIs and other foreign entities. The temporary regulations revise final regulations (TD 9610) under chapter 4 of the Internal Revenue Code.

As FATCA compliance deadlines draw closer, the IRS continues to incorporate various fixes to its regulations and forms. For example, on June 17, the IRS announced that it intends to issue technical corrections dropping the retail qualification in FATCA’s transitional rule for withholding on offshore payments of U.S.-source fixed or determinable annual or periodic income. Moreover, on June 19, the IRS announced updates to the instructions for Form W-8IMY, which is used by intermediaries and certain other entities to certify their status under FATCA.

Brandon Roman
Brandon Román advises domestic and international clients on a range of legal, legislative, and regulatory issues.
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Erin McGrain represents international and domestic clients on a range of legislative, administrative and policy matters.
06.16.2014

Tax and Retirement

LEGISLATIVE ACTIVITY

REID, PAUL WORKING ON REPATRIATION BILL TO FUND TRANSPORTATION INFRASTRUCTURE

On June 10, Senate Majority Leader Harry Reid (D-NV) and Senator Rand Paul (R-KY) indicated that they are working on legislation that would allow corporations to repatriate foreign earnings at lower rates, suggesting that this revenue could be used to fund improvements to transportation infrastructure. Senators Reid and Paul are basing their discussions on section 965 of the Internal Revenue Code (IRC), which was enacted in 2004 and provided for an optional, one-year 85 percent dividends received deduction for dividends paid by a controlled foreign corporation to a U.S. corporation. Majority Leader Reid has suggested setting the rate at 9.5 percent, which he estimated would yield $30.3 billion in the first two years; however, revenue losses in later years would offset this early gain, netting approximately $3 billion total over a 10 year period. In contrast, the Joint Committee on Taxation (JCT) estimates that a one-year reinstatement of section 965 would cost the government an estimated $95.8 billion over a 10 year period. While Senator Paul has not yet expressed support for the 9.5 percent rate, he has suggested that he is seeking a compromise between his preference for a permanent 5 percent rate on repatriated profits and Democrats’ desire for a temporary tax holiday. It is unclear whether Senators Reid and Paul intend for a repatriation proposal to serve as a long or short-term fix to replenish the depleted Highway Trust Fund.

Despite efforts to work out a compromise on repatriation, Senate Republicans do not generally support using such legislation to pay for highway spending. Notably, House Ways and Means Committee Chairman Dave Camp (R-MI) has also indicated that he opposes such a plan, as he would prefer to use revenues from repatriation to keep comprehensive tax reform revenue neutral.

warren’s student loan bill stalls in the senate

On June 11, the Senate decided not to move forward with Senator Elizabeth Warren’s (D-MA) bill (S. 2432) to refinance student loan debt with a minimum tax on high-income filers (the “Buffet Rule”). The bill, the Bank on Students Emergency Loan Refinancing Act, would impose a minimum effective tax rate on the adjusted gross income (AGI) of joint filers whose AGI exceeds $1 million ($500,000 for married individuals filing separately). The tax would phase in for joint filers with AGIs between $1 million and $2 million (between $500,000 and $1 million for married individuals filing separately), reaching 30 percent when fully phased in.

Regulatory ACTIVITY

IRS to issue corrections, faqs as FATCA EFFECTIVE DATE nears

As the Foreign Account Tax Compliance Act (FATCA) July 1 effective date draws near, the Internal Revenue Service (IRS) has announced that requirements of qualified intermediary (QI) agreements and withholding partnership (WP) agreements will be added to the requirements of a foreign financial institution (FFI) agreement. The IRS is also planning technical corrections to both final and temporary FATCA regulations. Reportedly, the IRS is examining: (1) temporary regulations (T.D. 9657) dealing with the rule for collateral for a withholding payment exception; (2) the descriptions of the QI and QI certification forms; and (3) the commercial activities test regarding the limitation on treatment as an exempt beneficial owner in section 1.1471-6. The corrections will likely be issued by July 1 or shortly thereafter.

Further, on June 11, the IRS indicated that audits to verify compliance with FATCA requirements are not likely to begin until early 2016, as it will take until then to process and prepare the information that the agency will receive beginning in 2015.

Brandon Roman
Brandon Román advises domestic and international clients on a range of legal, legislative, and regulatory issues.
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Erin McGrain represents international and domestic clients on a range of legislative, administrative and policy matters.
06.09.2014

Tax and Retirement

LEGISLATIVE ACTIVITY

SENATE FINANCE COMMITTEE outlines path forward on tax reform

On June 5, Senate Finance Committee Chairman Ron Wyden (D-OR) and Ranking Member Orrin Hatch (R-UT) announced the Committee’s next steps with regard to comprehensive tax reform. As part of its efforts, the Committee will hold three hearings during June and July focused on: (1) education tax incentives; (2) identity theft and taxpayer privacy protection; and (3) modernizing corporate taxation. According to Chairman Wyden and Ranking Member Hatch, “[w]hen it comes to tax policy, comprehensive tax reform is our ultimate objective.” In addition to these three hearings, the Committee will continue to explore how to address the depleted Highway Trust Fund “without diverting revenues from repatriation needed for tax reform.”

house to take up three tax extender bills

On June 6, House Majority Leader Eric Cantor (R-VA) announced that the House will consider three tax extender bills this week: (1) H.R 4457, which would make permanent the rule regarding business equipment depreciation under Section 179 of the Internal Revenue Code; (2) H.R. 4453, which would make permanent the reduced recognition period for built-in gains of S corporations; and (3) H.R. 4454, which would make permanent the rule regarding the basis adjustment to stock of S corporations making charitable contributions of property. Additionally, Leader Cantor announced that the House will consider a temporary fix to the depleted Highway Trust Fund, suggesting a reduction in the number of postal delivery days as an offset.

Regulatory ACTIVITY

IRS AND TREASURY TO RELEASE ADDITIONAL GUIDANCE BEFORE FATCA EFFECTIVE DATE

On June 3, Quyen Huynh, Associate International Counsel, U.S. Department of the Treasury (Treasury) announced that the Internal Revenue Service (IRS) and Treasury will be releasing additional guidance before the Foreign Account Tax Compliance Act’s (FATCA) July 1 effective date. First, the government will release instructions for various forms. The government will also release an updated foreign financial institutional (FFI) agreement to be consistent with a package of temporary regulations (T.D. 9657 and T.D. 9658) released in February. Additionally, modifications will be made to the qualified intermediary agreement, foreign withholding partnership agreement, and foreign withholding trust agreement to incorporate requirements under FATCA.

Brandon Roman
Brandon Román advises domestic and international clients on a range of legal, legislative, and regulatory issues.
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Erin McGrain represents international and domestic clients on a range of legislative, administrative and policy matters.
06.02.2014

Tax and Retirement

LEGISLATIVE ACTIVITY

WAYS AND MEANS MARKS UP SIX MORE tax BILLS, EXPECTED TO CONTINUE WORK ON EXTENDERS THROUGH SUMMER

On May 29, the House Ways and Means Committee held a markup of six bills (four extenders and two new provisions) seeking to make the following tax provisions permanent: (1) conservation contributions; (2) IRA distributions; (3) food inventory; (4) charitable contributions; (5) investment income of private foundations; and (6) bonus depreciation. This is the second round of bills the Ways and Means Committee has marked up relating to tax extenders. Democrats were generally supportive of the substance of the bills, but expressed concern about making policies permanent without providing any offsets. While all the bills were favorably reported out of Committee, each vote was along straight party lines.

Following the markup, Chairman Dave Camp (R-MI) stated that “[w]e are making progress on tax reform…[i]t may not be in a complete bill, but this is incremental progress.”  The Committee’s work on extending or making permanent more than 50 expired tax provisions is expected to continue into the summer.

Regulatory ACTIVITY

Financial institutions may initially use existing forms to sort entity accounts required by fatca

The Internal Revenue Service (IRS) has indicated that financial institutions will be permitted to use existing forms to sort their entity accounts through 2014 and later update the Foreign Account Tax Compliance Act (FATCA) identification status during the applicable due diligence period.  This announcement follows Notice 2014-33, providing that the IRS will treat calendar years 2014 and 2015 as a transition period during which it will consider institutions’ good-faith efforts to comply with FATCA when enforcing and administering the its due diligence, reporting, and withholding provisions.

Brandon Roman
Brandon Román advises domestic and international clients on a range of legal, legislative, and regulatory issues.
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Erin McGrain represents international and domestic clients on a range of legislative, administrative and policy matters.
05.19.2014

Tax and Retirement

LEGISLATIVE ACTIVITY

Tax extenders bill stalls in senate, timing now unclear

On May 15, the Senate was unable to garner the 60 votes needed to end debate on tax extenders legislation.  The bill, which would provide a two-year extension for certain tax extenders that expired on January 1, stalled as a result of Republican concerns over the amendment process.  Senate Finance Committee Chairman Ron Wyden (D-OR) suggested that the Senate may take up the bill again on Tuesday, May 20.  However, Chairman Wyden also indicated that Republicans must provide a list of amendments they intend to offer before the Senate will take up the bill.

senator Levin to inTroduce Anti-inversion bill

Last week, Senator Carl Levin (D-MI) announced that he plans to introduce anti-inversion legislation on Tuesday, May 20.  According to Senator Levin, the bill will be similar to a proposal in the Obama Administration’s FY2015 Budget Proposal, which calls for raising the required foreign ownership of stock to 50 percent for corporate inversions.  Senator Levin has also indicated that his proposal may have a two-year sunset provision, which would allow Congress additional time to address corporate tax inversions when implementing comprehensive tax reform.

According to a spokesperson for Representative Sandy Levin (D-MI), Ranking Member of the House Ways and Means Committee, he plans to introduce a companion anti-inversion bill in the House on the same day that Senator Levin introduces his legislation in the Senate.

Regulatory ACTIVITY

irs updates fatca FAQs

On May 13, the Internal Revenue Service (IRS) again updated its list of Foreign Account Tax Compliance Act (FATCA) FAQs.  Specifically, the IRS provided guidance on how trustees of trustee-documented trusts should register to participate in FATCA, indicating that these trusts should use the same procedures used by sponsors to register sponsored entities.

Brandon Roman
Brandon Román advises domestic and international clients on a range of legal, legislative, and regulatory issues.
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Erin McGrain represents international and domestic clients on a range of legislative, administrative and policy matters.
05.12.2014

Tax and Retirement

LEGISLATIVE ACTIVITY

senate to take up temporary tax extenders package; House Takes Different Approach

During the week of May 12, the Senate is expected to take up the EXPIRE Act (S. 2260), which provides a two-year extension for certain tax extenders, which expired on January 1.

The Senate’s approach for dealing with tax extenders differs significantly from that in the House. The House, which is out this week, is going “policy by policy” to determine which extenders should be made permanent, rather than pursuing a short-term, across-the-board solution like the Senate. For example, on May 9, the House passed the American Research and Competitiveness Act of 2014 (H.R. 4438), which would make permanent the alternative simplified research credit that expired in 2013. Following the vote, House Ways and Means Committee Chairman Dave Camp (R-MI) urged the Senate to take up similar legislation, noting that “[s]hort-term tax policies aren’t helping businesses hire new workers or grow the economy.”

senators Wyden, levin developing tax inversion bill

On May 8, Senate Finance Committee Chairman Ron Wyden (D-OR) announced that he is working on a proposal with Senator Carl Levin (D-MI) to crack down on corporate tax inversion, which allows companies to decrease their U.S. tax liabilities by moving their headquarters overseas. According to Chairman Wyden, this practice erodes the U.S. tax base, making comprehensive tax reform all the more difficult to accomplish. Although neither Chairman Wyden nor Senator Levin have released details on the bill, Senator Levin has suggested that he hope to release legislation this week.  Additionally, Representative Sandy Levin (D-MI), Ranking Member of the House Ways and Means Committee, has indicated that he would introduce similar legislation in the House.

Regulatory ACTIVITY

irs announces form instructions, guidance fixes to be complete by july 1; planning “reasonable audit” approach

On May 8, the Internal Revenue Service (IRS) announced that it plans to issue any remaining instructions for forms and non-substantive corrections to temporary regulations (T.D. 9657, T.D. 9658) before the Foreign Account Tax Compliance Act’s (FATCA) effective date of July 1. Additionally, on May 9, IRS Deputy Commissioner Michael Danilack announced that the IRS will not be developing new audit regimes, but will instead take a “reasonable and rational” audit approach to ensure that taxpayers are making a good-faith effort to comply with FATCA requirements.

Brandon Roman
Brandon Román advises domestic and international clients on a range of legal, legislative, and regulatory issues.
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Erin McGrain represents international and domestic clients on a range of legislative, administrative and policy matters.
05.05.2014

Tax and Retirement

Legislative Activity

House to Vote on legislation to permanently extend R&D tax Credit

During the week of May 5, the House of Representatives is set to vote on H.R. 4438, the “American Research and Competitiveness Act of 2014,” which is one of six bills considered during the House Ways and Means Committee’s markup of certain corporate tax provisions. The bill, which was favorably reported out of the House Ways and Means Committee in a 22-12 vote on April 29, would make permanent a simplified version of the research and development credit. Currently, it is unclear when the House will take up any of the other five bills or when the Committee will hold another markup on extenders provisions.

THIS WEEK’S HEARINGS:

  • Tuesday, May 6: The Senate Finance Committee will hold a hearing titled, “New Routes for Funding and Financing Highways and Transit.”
  • Wednesday, May 7: The House Ways & Means Committee will hold a hearing titled, “Internal Revenue Service Operations and the 2014 Tax Return Filing Season.”

Regulatory ACTIVITY

irs issues Guidance on Transition period for FATCA implementation

On May 2, the Internal Revenue Service (IRS) issued Notice 2014-33, which announces that 2014 and 2015 will be considered a transition period for purposes of enforcement and administration of the due diligence, reporting, and withholding provisions under the Foreign Account Tax Compliance Act (FATCA). According to the notice, during the transition period, the IRS will consider the extent to which a participating or deemed-compliant foreign financial institution (FFI), direct reporting nonfinancial foreign entity, sponsoring entity, sponsored FFI, sponsored direct reporting nonfinancial foreign entity, or withholding agent has made good-faith efforts to comply with FATCA requirements. Those entities that have not made good-faith efforts to comply will not be eligible for relief during the transition period. The notice also provides that Treasury and the IRS intend to further amend the regulations under sections 1441, 1442, 1471, and 1472.

Additionally, on May 1, the IRS released an updated list of frequently asked questions (FAQs) relating to FATCA, including questions and answers on responsible officers, branches and disregarded entities, and the registration process.

Brandon Roman
Brandon Román advises domestic and international clients on a range of legal, legislative, and regulatory issues.
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Erin McGrain represents international and domestic clients on a range of legislative, administrative and policy matters.
04.28.2014

Tax and Retirement

LEGISLATIVE ACTIVITY

ways and means to hold markup of six extender bills

On Tuesday, April 29, the House Ways and Means Committee will hold a markup of six bills to permanently extend the business tax provisions discussed in the Committee’s hearing on April 8. The bills are:

  • HR 4429, “To amend the Internal Revenue Code of 1986 to permanently extend the subpart F exemption for active financing income.”
  • HR 4438, “To amend the Internal Revenue Code of 1986 to simplify and make permanent the research credit.”
  • HR 4453, “To amend the Internal Revenue Code of 1986 to make permanent the reduced recognition period for built-in gains of S corporations.”
  • HR 4454, “To amend the Internal Revenue Code of 1986 to make permanent certain rules regarding basis adjustments to stock of S corporations making charitable contributions of property.”
  • HR 4457, “To amend the Internal Revenue Code of 1986 to permanently extend increased expensing limitations, and for other purposes.”
  • HR 4464, “To amend the Internal Revenue Code of 1986 to make permanent the look-through treatment of payments between related controlled foreign corporations.”

Such action is consistent with Committee Chairman Dave Camp’s (R-MI) assertion that he plans to go “policy by policy to determine which extenders should be made permanent.” As such, it is expected that the Committee will continue to hold similar hearings and markups over the coming months.

Regulatory ACTIVITY

irs issues minor correcting amendments to fatca regulations

On Monday, April 21, the Internal Revenue Service (IRS) issued minor correcting amendments to a set of rules (T.D. 9658, RIN 1545-BL18) relating to the withholding tax on certain U.S. source income paid to foreign persons; information and backup withholding on payments made to certain U.S. persons; and portfolio interest treatment. According to the IRS, it issued the amendments to correct errors in the instructions in the rules.

Brandon Roman
Brandon Román advises domestic and international clients on a range of legal, legislative, and regulatory issues.
avatar
Erin McGrain represents international and domestic clients on a range of legislative, administrative and policy matters.