On September 14, 2009, the Joint Committee on Taxation ("JCT") released a 255 page pamphlet (the "Pamphlet") that describes and analyzes the international tax proposals contained in President Obama's 2010 budget proposal. (The "Administration's International Tax Proposals")
The JCT is a Committee of the U.S. Congress. The JCT is composed of ten Members of Congress, five from the Senate Finance Committee and five from the House Ways and Means Committee. The responsibilities of the JCT include, among other things, the study, review and providing of recommendations related to pending tax proposals.
The Administration's Tax Proposals would have a significant impact on U.S multinational corporations in the pharmaceutical industry, including, among other things, the timing of deductibility of certain foreign related expenses; the ability to elect the U.S. tax status of foreign entities to facilitate international tax planning; and flexibility in foreign tax credit planning so as to tax optimize the cost of foreign dividend repatriation.
You might also be interested on a PwC webcast by the International Tax Services group on September 29th. You can find full details at: http://www.meetpwc.com/rsvp/invitation/invitation.asp?id=/m2c53c-42OG0CIDTRCFN