U.S. Tax Alert - 14 September 2009Administration and JCT release additional information on administration’s FY 2010 budget |
The Joint Committee on Taxation (JCT) released on 14 September 2009, their "Description of Revenue Provisions Contained in the President’s Fiscal Year 2010 Budget Proposal Part 3: Provisions Related To The Taxation of Cross-Border Income and Investment" (link below). Parts 1 and 2 were released on 8 and 9 September, respectively, and address the administration’s individual income tax, estate and gift tax, and business tax proposals. Part 3 summarizes the administration’s international tax and compliance proposals.
OMB issues new revenue estimates of administration’s FY 2010 budget
On 25 August 2009, the Office of Management and Budget (OMB) published revised revenue estimates of the revenue provisions in the Administration’s FY 2010 Budget in the OMB’s report to the House of Representatives, Mid-Session Review: Budget of the U.S. Government (link below). However, the updates do not provide additional information on the international tax proposals themselves.
| Provision | Revenue raised (billions) | ||
|---|---|---|---|
| Administration 5/2009 Projection | JCT 6/2009 Projection | Administration 8/2009 Projection | |
| Reform check-the-box rules for foreign entities | 86.5 | 31.1 | 36.5 |
| Defer certain U.S. income tax deductions<</td> | 60.1 | 51.5 | 52.9 |
| Foreign tax credit reform: single pool of §902 credits | 24.5 | 45.6 | 24.5 |
| Foreign tax credit reform: matching foreign income and taxes | 18.5 | 10.2 | 18.4 |
| Foreign tax credit reform: dual capacity taxpayers | 4.5 | 7.2 | 4.9 |
| Definition of “intangible property” for §367(d) and §482 purposes | 2.9 | 1.0 | 1.0 |
| Repatriation of earnings in certain cross-border reorganizations | 0.3 | 0.4 | 0.3 |
| Repeal of 80/20 Company rules | 1.2 | 0.8 | 1.3 |
| Earnings stripping | 1.2 | 1.5 | 1.2 |
| Prevent avoidance of dividend withholding taxes in equity swaps, securities loans, repos | 1.4 | 1.2 | 1.2 |
| Enforcement proposals (effective beginning after December 31 of year of enactment) | 8.7 | 8.8 | 8.7 |
| Total for all international proposals | 209.8 | 159.3 | 150.9 |
Links
Part 3 (JCS-4-09) is available on the JCT website at www.jct.gov/publications.html?func=startdown&id=3578
The full mid-session release by the OMB is available at http://www.whitehouse.gov/omb/assets/fy2010_msr/10msr.pdf
Global Tax Alert - United States
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