Tax Foundation: Rethinking U.S. Taxation of Overseas Operations

By Jonathan Prokup Our in-house and private-practice corporate readers will likely enjoy one of the Tax Foundation's newest reports: Rethinking U.S. Taxation of Overseas Operations. As the abstract describes: The United States produces a third of the world's wealth but contains less than 5 percent of the world's population. This disparity pushes many U.S. businesses … Continue reading Tax Foundation: Rethinking U.S. Taxation of Overseas Operations

The Moment of Truth: Is Tax Reform Coming?

By Jonathan Prokup Recalling one of our first blawg posts, the topic of tax reform could be described in much the same terms as the codification of economic substance (prior to its codification, anyway): "a cousin of Bigfoot and the Loch Ness Monster – often spotted, but never confirmed."  Reform commissions come and go with … Continue reading The Moment of Truth: Is Tax Reform Coming?

Say That Again: A Summary of AJACTLA

By David Shakow If you haven’t memorized the 433 pages of the latest version of the American Jobs and Closing Tax Loopholes Act of 2010 (undoubtedly named to allow for the euphonious acronym, AJACTLA), you are denying yourself a unique treat.  (To get the true flavor, don’t forget the fifteen pages of amendments included with … Continue reading Say That Again: A Summary of AJACTLA

More on Wyden-Gregg’s Interest Disallowance Rule

By Jonathan Prokup and David Shakow You might recall our prior post on the Wyden-Gregg tax reform proposal in which we discussed the proposed limitation on corporate interest deductions.  To summarize, the legislation would limit the deductibility of payments on corporate debt to the amount of the interest in excess of the annual rate of … Continue reading More on Wyden-Gregg’s Interest Disallowance Rule

The Wyden-Gregg Tax Reform Bill – Part I (cont’d)

By Jonathan Prokup and David Shakow We previously discussed how the Wyden-Gregg bill proposes reducing interest deductions to the extent the interest simply compensates for inflation.  Inflation affects tax calculations in two ways.  First, it affects the dollar figures in the Code so that, for example, when your wages keep up with inflation, but you … Continue reading The Wyden-Gregg Tax Reform Bill – Part I (cont’d)