Obama Plan Re-Introduces International Tax Proposals

On September 19, 2011, President Obama unveiled his plan to reduce the federal deficit in a document entitled, Living Within Our Means and Investing in the Future: The President’s Plan for Economic Growth and Deficit Reduction, (the Deficit Plan). The Deficit Plan contains many proposals included in the administration’s FY 2012 Budget proposals, including almost all of the international tax revenue proposals, including:

  • Currently taxing “excess returns” earned by a CFC with respect to certain intangible property transferred to it by a related U.S. person;
  • Clarifying the definition of intangible property under Section 936(h)(3)(B) for purposes of Sections 482 and 367(d);
  • Deferring the deduction of interest expense related to foreign-source income not currently subject to U.S. federal income tax; and
  • Tightening the Section 163(j) “earnings-stripping” rules for certain expatriated entities.

The professionals at Align can assist your organization in assessing the impact of these initiatives. Align Global Consulting is a Raleigh, North Carolina-based globalization firm that helps clients expand globally or improve existing operations by providing creative legal and tax solutions to address commercial, trade, investment and regulatory matters. Align's comprehensive list of services includes global structuring, global business transactions, cross-border M&A transactions, and international tax planning for outbound and inbound investment. Align assists companies in all stages of growth, from emerging growth companies to the Fortune 100. With "big firm" credentials and experience, Align handles matters traditionally entrusted to larger firms, while maintaining a commitment to the lost art of one-on- one client service. Click here for contact information for Align Global Consulting.


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