Eversheds Sutherland Tax Reform Law Blog
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The Topsy Turvy Status of Inversions – Levins Move Forward, Wyden and Pfizer Move Back

Senator Carl Levin (D-Mich.) and 13 other Senate Democrats introduced legislation on May 20th that would significantly reduce the ability of U.S. companies to expatriate.  The Stop Corporate Inversions Act of 2014 would generally enact President Obama’s budget proposal targeting corporate inversions (see our prior post) by reducing from 80% to 50% the post-inversion ownership...

Irish Companies May Soon Have to Reside Somewhere Rather Than Nowhere

A structuring technique used by multinational corporations to avoid being a resident of any taxing jurisdiction by incorporating in Ireland may be coming to an end.  According to Michael Noonan, the Irish Finance Commissioner, a proposal to end “stateless companies” will be included in the 2014 Irish Finance Bill, which is scheduled for release the week of October 24, 2013. Although...

Senator Levin vs. ITI: A War of Words Over International Tax Reform

Senator Carl Levin (D-Mich.) and a tech industry association are having a heated back-and-forth over Sen. Levin’s proposal for international tax reform. On September 19, 2013, Sen. Levin introduced the Stop Tax Haven Abuse Act, S. 1533, the most recent version of legislation he has introduced multiple times.   According to Sen. Levin’s office, the bill would generate approximately $220...

“Max and Dave” Road Show Hits Silicon Valley; Camp Not Running for Senate

Congress’s two top tax writers, Rep. Dave Camp (R-Mich.) and Sen. Max Baucus (D-Mont.), took their “Simpler Taxes for America Tour” to Silicon Valley on Monday, visiting chip-making giant Intel Corp. and mobile-payment innovator Square Inc. to discuss reforming the U.S. tax code.  In July, Rep. Camp and Sen. Baucus kicked off a national tour to gather feedback from Americans – ranging...

Growing Concerns Over “Stateless Income” Make It a Target for International Tax Reform

Tax planning of multinational corporations designed to generate what is being referred to as “stateless income”—income sourced in low-tax jurisdictions or in no source country at all— continues to be scrutinized both in the United States and abroad.  Senator Carl Levin (D-MI), a major proponent of tax reform, has held Congressional hearings over the past several months on the issue of...

Bipartisan Pair of Senators Eye Corporate Tax Reform as Part of Sequester Solution

Senator Carl Levin (D-MI) has announced that he is working with Senator John McCain (R-AZ) on a plan to close corporate tax loopholes as part of a fiscal package aimed at replacing the budget sequester.  Speaking at a conference in Washington, Sen. Levin said that he and Sen. McCain want to prevent the use of offshore tax havens by multinational corporations, a practice that Sen. Levin...

Tides of Change: Senators Introduce Bill to Increase Transparency of U.S. Corporate Ownership

In an effort to increase transparency and combat tax evasion, Senators Charles Grassley (R-IA) and Carl Levin (D-MI) introduced legislation on August 1 that would require states to obtain the identities of individuals who organize corporations and other business entities under their laws.  Sen. Grassley is ranking member of the Senate Judiciary Committee and a past chairman of the...

U.S. Pushes Global Information Exchange at G8 Summit

The U.S. hopes to build international consensus around combating tax evasion and corporate profit shifting at this week’s G8 meeting in Northern Ireland.  Specifically, the U.S. is pushing a single global standard of information exchange, based on the Foreign Account Tax Compliance Act (better known as FATCA).  In comments to reporters, President Obama’s special assistant for...