Legal Alert: Billionaires, BEAT, and Basis-Shifting – 2023 Green Book proposes tax changes affecting corporations, partnerships and individuals

On March 28, 2022, the Biden Administration released the 2023 Fiscal Year Budget (the 2023 Budget). It is important to note that the Budget assumes the Build Back Better Act (the BBBA) will be enacted as passed by the House on November 19, 2021 (other than Section 137601 of the BBBA, which would increase the cap on the federal tax deduction for state and local income and real estate taxes (the SALT cap)). The 2023 Budget contains proposals that would be in addition to those included in the BBBA. Highlights of the BBBA are covered in prior alerts located here and here.

Among many other items, the 2023 Budget proposes several tax reforms that are projected to “more than offset the cost of new investments” and “reduce the deficit this year to less than half of what it was” in 2020.1 The 2023 Budget was followed by the release of the Treasury’s Green Book, which provides explanations of the Biden Administration’s revenue proposals.

Read more about the key international and corporate tax highlights of the 2023 Budget in our legal alert here.

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