The Treasury Department's “Green Book,” released February 13, 2012, outlines the Obama Administration’s budget proposals for fiscal year 2013, with few changes to the international tax proposals carried forward from the previous year's budget. However, the budget does include four new proposals.
For US multinationals, the focus in the Administration's FY 2013 budget remains on outbound IP transfers and base erosion. The key items continue to be the "excess return" proposal for IP transferred outside the United States and proposed limitations on shifting income through IP transfers. Other major items in the international tax area include the familiar proposals for deferral of foreign-related interest expense, pooling for section 902 foreign tax credits, and the extension of "controlled foreign corporation look-through" until the end of 2013. This Newsalert provides an overview of the relevant international tax provisions in the budget.