The House version of the tax extenders bill (the "Protecting Americans From Tax Hikes Act of 2015") has now been posted online.
Of note to international tax buffs, the "active financing" exception to applying subpart F to financial income earned abroad by U.S. companies' foreign subsidiaries is made permanent by section 128 of the still-just-proposed Act.
Also, section 954(c)(6), the so-called "look-through" rule that often permits U.S. companies to avoid subpart F on foreign-to-foreign tax planning, without requiring the tedium of using hybrid entities, is extended through the end of 2019, by Act section 144.
The active financing rule's initial enactment and frequent extension have been popularly attributed to GE, at least as a key organizing player. GE presumably doesn't care about this rule any more, given their recent restructuring, but evidently it still has friends.
Extending section 954(c)(6) could certainly be viewed as in tension with the spirit of the OECD BEPS project, but it's not as if this makes it a surprise.
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4 comments:
International tax range (as well recorded in the journal of Economics) was the highest level in 2016. Last year, there was a statistics report that could be downloaded via the link in Education vs Economics Portal.
Then, there was a little bewilderment with the financial course at College of New Rochelle.
thanks for post
Accounting代写的难点在于以下几个方面:
1）在工作量和技术上，它和工程课程没有什么区别，紧张，容易突然死亡。我想说，教科书的第一章说，一个好的会计的基本素质是一个强壮的身体?
2）在一个成功的会计所必需的管理和人际交往能力方面，也要求会计人员不要太死板。大多数大公司的ceo要么是会计师，要么懂会计，所以他们可以在没有会计师领导的情况下妥善处理企业和资本的关系。业内有句老话:没有利润的生意是痛苦的，没有现金的生意是致命的。例如，一个市值100亿、利润数亿元的公司可能会因为账面上只有2000万元的营业额而破产。所以一个公司领导不懂会计，不懂财务管理是很可悲的。
The House has introduced the Protecting Americans From Tax Hikes Act of 2015, making the "active financing" exception permanent and extending section 954(c)(6) through 2019. While these tax extenders assist U.S. companies, they could clash with OECD BEPS goals. Much like playing Bitlife , navigating taxes can be strategic yet complicated.
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