International Tax Reform May Still Be a Possibility; Treasury Focused on FATCA, PTPs
Tax Reform Still in Ryan’s Sights Despite Boehner’s Departure
Last week, following the sudden announcement by House Speaker John Boehner (R-OH) that he would be stepping down from Congress at the end of October, House Ways and Means Committee Chairman Paul Ryan (R-WI) and various other Committee members quickly confirmed that the Committee would continue forward with its plans to do international tax reform this year. While details of what the plan will look like have not yet been released in full, earlier this year Representatives Charles Boustany (R-LA) and Richard Neal (D-MA) released a draft of their “Innovation Box” proposal, which would be one of the major incentives called for under the plan to encourage businesses to domicile in the U.S. Though the likelihood and timing of international tax reform is presently uncertain, Senate and House tax-writers are communicating regarding the matter on a regular basis and have not discounted the possibility.
Ways and Means to Markup Reconciliation Legislation
On Tuesday, September 29, the House Ways and Means Committee is scheduled to mark up yet to be detailed legislative proposals in response to the reconciliation directive in section 2002 of S. Con. Res. 11, the FY 2016 Budget Resolution. Pursuant to the directive, the Ways and Means Committee is required to submit proposals to reduce the deficit by at least $1 billion from FY 2016 to 2025.
This Week’s Hearings:
- Tuesday, September 29: The House Ways and Means Committee will hold a markup of legislative proposals in response to the reconciliation directive included in section 2002 of S.Con.Res. 11.
- Tuesday, September 29: The Senate Finance Committee will hold a hearing titled “Financial and Economic Challenges in Puerto Rico.”
- Wednesday, September 30: The House Ways and Means Subcommittee on Oversight will hold a hearing on the Department of Labor’s Fiduciary Rule.
- Thursday, October 1: The Senate Finance Committee will hold a hearing titled “Improper Payments in Federal Programs.”
Regulatory Activity
U.S. Signs Competent Authority Agreement with UK, Australia
Last week, on Thursday, September 24, the Competent Authority of the United States announced that it has signed Competent Authority Arrangements (CAA) with the United Kingdom and Australia – two jurisdictions with which it has entered into intergovernmental agreements (IGAs) under the Foreign Account Tax Compliance Act (FATCA). These are the first such arrangements to be signed, though the Competent Authority expects numerous other CAAs to be enacted in the near-term. According to Internal Revenue Service (IRS) Commissioner John Koskinen, “[t]he signing of these Competent Authority Arrangements marks another significant milestone in the international effort to gain proper reporting of offshore accounts and income…Together in partnership with other tax authorities, we are demonstrating how far we have come in the fight against offshore tax evasion.”
IRS to Hold Hearing on PTP Qualifying Income Proposed Regulations
On Tuesday, October 27, the IRS will hold a public hearing on proposed regulations dealing with section 7704(d)(1)(E) of the Internal Revenue Code relating to qualifying income from exploration, development, mining or production, processing, refining, transportation, and marketing of minerals or production, processing, refining, transportation, and marketing of minerals or natural resources. The IRS has requested that all outlines of the topics to be discussed be submitted by October 7.
