As President Obama and tax policy specialists discuss ways to rein in a ballooning US debt, a national sales tax and changes to the corporate tax rate are beginning to look promising. By Elizabeth Bearese
Schedule UTP has been been the subject of intense debate within corporate tax circles since the IRS announced the programme in January 2010. However, this programme is just the latest in a long line of IRS initiatives aimed at enhancing taxpayer transparency. Eli Dicker, chief tax counsel of the Tax Executives’ Institute, questions whether or not Schedule UTP will fundamentally alter the landscape.
The anti-hybrid rules in the Canada-US income tax treaty are an example of good intentions gone astray. Jeffrey Trossman, tax partner at the Canadian law firm of Blake Cassels & Graydon discusses important changes contained in the treaty’s Fifth Protocol, and explains how they affect inbound investments into Canada.
As the US economy continues to sputter, it is perhaps not surprising that Congress and the administration have looked to change the country’s international tax rules to increase revenue. David Forst and Adam Halpern, partners at Fenwick & West, explain some of these changes, including legislative developments and new case law that will have implications for multinational corporations.