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Energy Tax Reform: Current Updates And What It Means For Companies In The Energy Sector

Energy tax reform has been the subject of three recent, and very significant, administrative and legislative proposals: The President’s 2015 budget, released on March 4, 2014; The comprehensive tax reform plan released on February 26, 2014, by Representative Dave Camp (R-Mich.), chairman of the House Ways and Means Committee; and The energy tax discussion draft released on December 18,...

To Extend or Not to Extend: Hatch Reiterates Need for Individual Scrutiny of Tax Breaks

The end of 2013 saw the expiration of more than 50 temporary tax cuts, including the research and development credit, various renewable energy credits, provisions allowing accelerated depreciation of certain business assets, and certain international tax provisions.  In past years Congress has allowed these provisions to lapse, only to retroactively renew them for limited periods...

Tax Foundation Skeptical About Retroactive Tax Increases in Baucus Discussion Drafts

In a December 9 report, the Tax Foundation analyzed three tax increases contained within Senator Max Baucus’s (D-Mont.) recent tax reform discussion drafts.  Among the revenue-generating measures Sen. Baucus has proposed to help pay for a reduction in the corporate tax rate, the Tax Foundation identified these three as having a retroactive effect: the deemed repatriation of certain...

Senator Baucus To Be Nominated to China Post; Future of Tax Reform in Doubt

Politico reports President Barack Obama is expected to nominate Senator Max Baucus (D-Mont.) as the next ambassador to China.  News of the expected nomination came on the same day Sen. Baucus released his fourth tax reform discussion draft, focused on modernizing and streamlining energy tax incentives.  While the nomination is not yet official, it is apparently a “done deal” according...

Baucus Proposes Major Overhaul to Energy Incentives

Senator Max Baucus (D-Mont.) issued a new discussion draft this week that proposes to overhaul federal tax incentives for energy.  The proposal would replace most of the more than 40 existing incentives with two new tax credits for the cleaner production of electricity and transportation fuels. Under the proposed clean electricity tax credit, any facility producing electricity that is...

Baucus Releases Energy Discussion Draft

Senator Max Baucus (D-Mont.) released a discussion draft on energy tax reform, his fourth tax reform discussion draft released in the past month.  The following link to the documents released by the Senate Finance Committee today: one-page summary extended summary legislative language JCT...

AICPA Opposes the Limitations on the Availability of Cash Method of Accounting under Baucus’s Proposal

On December 5, the American Institute for CPAs (“AICPA”) detailed their views on Senate Finance Committee Chairman Max Baucus’s (D-Mont.) tax reform discussion draft on tax accounting.  AICPA supports the expansion of the number of taxpayers that may use the cash method of accounting, and had concerns regarding Sen. Baucus’s proposal restricting the availability of the cash method of...

Baucus Discussion Drafts – Where’s the Rate?

The issuance of three tax reform discussion drafts by Senator Max Baucus (D-Mont.) within the last two weeks has left many U.S. businesses wondering, “Where’s the Rate?”.  While Sen. Baucus has said that he wants to reduce the corporate tax rate to less than 30 percent from the current 35 percent, the discussion drafts, which include proposals for international tax reform and the...

Senate Finance Committee Chairman Baucus Releases International Business Tax Reform Discussion Draft

Highlights of Discussion Draft On November 19, 2013, Senate Finance Committee Chairman Max Baucus (D-Mont.) released a “Discussion Draft” of international tax reform proposals.  The Discussion Draft proposes significant changes to the taxation of foreign income, including substantially expanding the definition of subpart F income, an immediate 20% tax on certain unrepatriated foreign...

Impact of International Tax Reform Proposals on U.S. Insurance Companies

On November 19, retiring Senate Finance Committee Chairman Max Baucus (D-Mont.) released a “Discussion Draft” setting forth his international tax reform proposals.  Of note, the Discussion Draft includes several proposals that target the international operations of U.S. insurance companies and international insurance groups with U.S. owners.  Specifically, those proposals would: Make...

Baucus Releases Discussion Draft on Cost Recovery and Accounting Tax Reform

Senator Max Baucus (D-Mont.) released a new tax reform discussion draft on cost recovery and accounting rules, with the stated goal of a simpler, fairer system that promotes tax neutrality.  The draft proposals address the rules governing depreciation of tangible and intangible assets, as well as certain tax accounting rules and rules affecting small businesses.  Significant proposals...

Mixed Reaction to Baucus International Discussion Draft

Following the release of Senator Max Baucus’s (D-Mont.) discussion draft on international tax reform, reaction from members of Congress and the business community is mixed.  Sen. Baucus’s counterpart in the House, Representative Dave Camp (R-Mich.), quickly praised Baucus for “his continued commitment to advancing tax reform forward,” but did not comment on the substance of Baucus’s...

Camp Tax Reform Bill Appears Unlikely in 2013 (and Possibly 2014)

It appears that House Ways and Means Committee chairman Dave Camp (R-Mich.) will not meet his self-imposed deadline of moving a tax reform bill through the Committee in 2013. Following Rep. Camp’s meeting last Thursday with Speaker of the House John Boehner (R-Ohio) and other top House Republican leaders, the prospect of Rep. Camp introducing a tax reform bill in 2013 appears unlikely...

Baucus Releases International Tax Draft

Senator Max Baucus (D-Mont.) has released his international tax reform discussion draft.  Links to the materials are below. A one-pager on the discussion draft A longer summary of the discussion draft The “common” section of the discussion draft Option Y of the discussion draft Option Z of the discussion draft Technical explanation of the discussion draft by the Joint...

Senate Finance Discussion Draft Topics: Tax Administration; International Taxation; Cost-Recovery Accounting

The Senate Finance Committee discussion drafts on tax reform will cover international tax rules, tax administration, and cost-recovery accounting, according to Tax Analysts.  Details are sparse, but Tax Analysts reports that the international draft will include a “round tripping” rule regarding asset transfers to avoid taxes, a dividends received deduction, a mandatory repatriation...

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