From your keyboard to Jack Lew’s eyes. Of course, Congress can, and certainly has, stopped Treasury from acting quickly – from their 501(c)(4) investigation to efforts to limit the IRS budget. I am sure such efforts will continue. Treasury and IRS also have their hands full implementing the Affordable Care Act’s tax provisions. The extra work will be, to turn a phrase, taxing. They might also slip into an appropriation that interest arrangements between subsidiaries may not be considered equities. While we all hope that they go in the oppostite direction, I am sure the donors will have their say. If there were a form that these entitites fill out on a regular basis, then ideally we could put something on that form and it becomes regular enforcement, although even that would still have a comment period. You can’t just change the Instructions on interest without anyone noticing and the Tax Court will certainly be the venue for the final resolution of this. I still favor a VAT as the solution to making sure that profits are taxed with labor – however Congress certainly won’t be passing that anytime soon, to the disappointment of myself, Michael Graetz (who wrote about it this week) and Bruce Bartlett. - See more at: taxvox.taxpolicycenter.org/2014/08/15/can-obama-slow-corporate-inversions-yes-can/#comment-270392
Posted on: Fri, 15 Aug 2014 23:50:33 +0000
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