Subscribe to the Tax Headline RSS feed | Subscribe to the Tax Headline feed via EmailInternational Revenue Raisers in Tax Extenders Bill Seen Constraining Foreign Tax Credit, Drawing Fire
May 27, 2010 in Daily Tax Report · Leave a Comment
The international revenue raisers in legislation (H.R. 4213) to extend expiring tax provisions would constrain the ability of U.S. multinationals to utilize the foreign tax credit and are a major reason for the business community’s opposition to the bill, practitioners told BNA in interviews May 25 and 26.
Unveiled May 20, the American Jobs and Closing Tax Loopholes Act contains a host of pay-fors aimed at addressing perceived cross-border abuses (97 DTR GG-1, 5/21/10). House leaders said they plan to bring the extender legislation to the floor for a vote May 27 (see related report in this issue).
Both Joseph Calianno, Grant Thornton LLP, Washington, D.C., and Phil West, Steptoe & Johnson LLP, Washington, D.C., said in separate interviews that two key provisions, one dealing with covered asset acquisitions under tax code Section 338 and one addressing tax planning that uses a so-called “hopscotch” rule under Section 956, would limit use of the foreign credit and are a significant issue for corporate taxpayers.
