International Tax Changes Take Flight

The House of Representatives passed, and the President signed into law, H.R. 1586, the "FAA Air Transportation Modernization and Safety Improvement Act," which curiously became the chosen vehicle for Congress and the Administration to provide assistance to states with budget shortfalls while paying for that assistance with changes in a number of international tax provisions.  … Continue reading International Tax Changes Take Flight

Certain Uncertainty: Congress Juggles Tax Proposals

By Jonathan Prokup Although death and taxes might, according to Benjamin Franklin, be the only certainties in this world, Congress is surely striving to add another - that is, the certainty of uncertainty.  Congress, it seems, is committed to keeping taxpayers in as much doubt as possible for as long as possible about the status … Continue reading Certain Uncertainty: Congress Juggles Tax Proposals

The Extenders Bill Is Dead. Long Live The Extenders?

By Jonathan Prokup Now that the tax extenders legislation has died, what’s next?  At least some of the provisions (e.g., the new tax regime for “carried interests”) are likely to find their way into future legislation.  But what about the tax extenders themselves, such as the look-through rule of section 954(c)(6) and the section 41 … Continue reading The Extenders Bill Is Dead. Long Live The Extenders?

Reps. Waxman and Stupak: Beware IRC Sec. 6103?

By Jonathan Prokup President Obama's health-care legislation is becoming more of a tax issue on a daily basis.  In addition to the codification of economic substance (discussed here; see also yesterday's TNT story featuring our own Phil Karter) contained in the reconciliation bill, the consequences of the legislation seem to be increasingly a matter of … Continue reading Reps. Waxman and Stupak: Beware IRC Sec. 6103?