BNA INSIGHTS: Covered Asset Acquisition Proposal: Sanctioning International Double Taxation?

Proposed legislation in the American Jobs and Closing Tax Loopholes Act of 2010 (H.R. 4213; hereinafter the “Bill”) would deny…

Carried Interest Tax Increase, S Corporation Curbs Softened in New Tax Extenders Proposal by Senate Finance Panel Chair Baucus

Senate Finance Committee Chairman Max Baucus (D-Mont.) June 16 introduced a new substitute amendment (S. Amdt. 4369) to the tax extenders bill (H.R. 4213) that would…

Senate Majority Leader Reid Seeks to Limit Debate, Pass Tax Extenders Legislation by Week’s End

Senate Majority Leader Harry Reid (D-Nev.) filed a motion June 14 to invoke cloture on the tax extenders bill (H.R. 4213) in an effort to complete the…

Carried Interest Tax Hike Passes House in Tax Extenders Bill; Senate Outlook Unclear

The House voted 215-204 May 28 to extend dozens of popular tax cuts through the end of 2010 and raise taxes on investment fund managers and businesses with foreign income…

International Revenue Raisers in Tax Extenders Bill Seen Constraining Foreign Tax Credit, Drawing Fire

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…

Business Groups Oppose Tax Extenders Bill, Put Pressure on Democrats on Eve of House Vote

Business organizations May 24 lashed out against congressional Democrats’ tax extenders and jobs bill (H.R. 4213) set for House floor consideration, saying that its permanent tax increases on…

Tax Extenders Bill Seen Raising $11 Billion from Rules on Self-Employment Taxes

Congress’s proposed changes to the treatment of self-employment taxes on professional service providers are expected to raise $11.2 billion in new revenues for the federal government to help pay for…

Government Still Looking at Asset Threshold Issue in Uncertain Tax Positions Proposal

The government continues to wrestle with the question of how a $10 million asset threshold for those required to disclose uncertain tax positions under a new proposal will apply to…

IRS Provides Guidance on Determining Eligibility for Small Firm Health Care Credit

The Internal Revenue Service May 17 provided comprehensive guidance (Notice 2010-44) on a small-employer tax credit included in recently enacted health care reform legislation…

Leeway Urged for Some Foreign Payments under Generator Rules

Loss sharing or joint tax settlements permitted under foreign law should not automatically result in foreign payments being considered “noncompulsory” under rules to crack down on deals to…

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