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Senate Passes 2014 Tax Extenders, White House Opposition Unlikely

On December 16, in a vote of 76 to 16, the Senate passed the long-anticipated “extenders bill,” extending 55 tax provisions that expired at the end of 2013.  The bill had been passed by the House of Representatives on December 3, 2014 and now heads to the President’s desk where it is expected to be signed into law. As a one-year extension of tax provisions that expired on...

Lew: Inversion Guidance Coming “Very, Very Soon,” Rather than Just in the “Very Near Future”

Anti-inversion guidance from Treasury is now a near-certainty, but when they arrive and how they will operate remains a mystery.  Treasury Secretary Jacob Lew used strong language to warn corporations against inverting in a September 17th interview with Bloomberg Television.  “Any company considering an inversion is now on notice that there is action that is going to be taken,” Lew...

Senator Wyden Renews Push for Tax Extenders

The Congressional tax agenda for the end of 2014 is now clear: tax extenders and inversions.  Even as inversions dominate the news, Senate Finance Committee Chairman Ron Wyden (D-Ore.) is continuing his push to pass legislation which extends expired tax provisions.  On September 15, Senator Wyden issued a statement on the need to renew expired tax provisions, stating that the actions...

Tax Extenders Debate is Extended — EXPIRE Act Stalls in the Senate

– Sen. Ron Wyden’s (D.-Ore.) EXPIRE Act, which would have revived several expired tax provisions (see prior post here), has been stalled in the Senate.  Despite broad bipartisan support for the EXPIRE Act, an apparent disagreement over amendments is preventing a vote on final passage. Senate Republicans proposed a number of amendments to the bill, including the repeal of the...

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...

Senate Extenders Legislative Language Released

Almost a month after the Senate Finance Committee approved legislation which would extend expired tax provisions (see our prior post), Chairman Ron Wyden (D-Ore.) finally introduced in the Senate the legislative language of the bill.  S. 2260, the Expiring Provisions Improvement, Reform, and Efficiency Act of 2014, or the EXPIRE Act, was introduced on April 28, and the text is...

Finance Chairman Releases Extenders Package; Drops Look-Through (or Maybe Not)

Update 2: The two-year extension of the look-through provision was officially added back into Sen. Wyden’s extenders package. Update: Dropping look-through lasted approximately 6 hours today.  The extenders package released this morning would not have extended the related party look through rule as discussed in the original post, but by 4 PM, a two-year extension of the look-through...

Wyden Hoping to Revive Tax Code “Carcass”

No one can accuse Ron Wyden (D-Ore.) of lacking creative metaphors.  The new Senate Finance Committee Chairman described the Internal Revenue Code as a “dysfunctional, rotting mess of a carcass,” while discussing his tax reform agenda on February 7 at the Conference on Growing Income Inequality in Los Angeles.  Sen. Wyden stressed his desire for a tax code “where everybody has a chance...

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...

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...