SFC Chairman Baucus discussion draft features CFC minimum tax options

November 2013


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.

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Doug McHoney
Co-leader, US Integrated Global Structuring team
Tel: +1 (312) 298 2527

Calum Dewar
Co-leader, US Integrated Global Structuring team
Tel: +1 (646) 471 5254

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