SFC Chairman Baucus discussion draft features CFC minimum tax options

November 2013

Overview

Senate Finance Committee Chairman Max Baucus (D-MT) recently released a comprehensive international tax reform discussion draft. Chairman Baucus stated that the discussion draft reflects Democratic and Republican proposals and concepts put forth in the past three years to “fix a broken system” and “motivate businesses to bring jobs and money back to the US.”

The discussion draft includes a wide variety of additional proposals, many of which would significantly change the US federal income tax system. Proposals include a measure to tax currently certain foreign earnings of controlled foreign corporations, statutory language for two differing regimes that would generally impose current taxation on all CFCs’ income at a minimum rate and a one-time tax on pre-effective date deferred earnings of foreign subsidiaries that have not been previously subject to US federal income tax.

Contact us

Doug McHoney
Outbound Co-leader, International Tax Services
Tel: +1 (312) 298 2527
Email

Calum Dewar
International Tax Outbound Services co-leader
Tel: +1 (646) 471 5254
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