Friday, April 2, 2021

Biden Infrastructure Plan: American Jobs Plan | Tax Foundation

Biden Infrastructure Plan: American Jobs Plan | Tax Foundation

Ahead of President Joe Biden 's speech in Pittsburgh on Wednesday evening, the White House has released a fact sheet on the proposed American Jobs Plan to fund additional spending on infrastructure and R&D. The proposal's tax increases on corporations are among the most harmful options to pay for the increased spending.

Increase the federal corporate tax rate from 21 percent to 28 percent and tighten inversion regulations.

Raise the tax on Global Intangible Low Tax Income (GILTI) to 21 percent, calculate it on a country-by-country basis, and eliminate the exemption of a 10 percent return on tangible investment abroad (QBAI).

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Publisher: Tax Foundation
Date: 2021-03-31T16:38:39-04:00
Twitter: @taxfoundation
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Quite a lot has been happening:

Biden's selfish plans on climate change | TheHill

Still, both plans ignore a solution to cut carbon that might pass under reconciliation — a carbon tax. Although the tax would be better for the public and the planet, it likely would not be as politically expedient for President Biden and his allies.

A carbon tax would be imposed on the production of oil, gas, coal, and anything else that results in carbon emissions. Much of the tax would be passed on to these products' ultimate users, whether big businesses or individuals. This would give them incentives to reduce their direct and indirect contribution to carbon emissions.

Publisher: TheHill
Date: 2021-04-02T08:30:08-04:00
Author: Richard Schmalensee and David Schoenbrod opinion contributors
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Common Reporting Standard: a View From Chile, Peru and Colombia

Santiago Arbouin, Rolando Cevasco, Diego Garcia and Carlos Chirinos of CMS provide an overview of the progress of the implementation of the Common Reporting Standard in Chile, Peru and Colombia.

The Common Reporting Standard (CRS) seeks to implement a system that facilitates the tax information exchange between Organization for Economic Co-operation and Development (OECD) countries which will accede to it. Although it is an anti-fraud and anti-tax evasion tool like the Foreign Account Tax Compliance Act (FATCA), the CRS is a multilateral system that is not limited to bilateral information reporting with the U.S.

Twitter: @tax
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Energy Industry: Carbon Credit Product Tax Credits

The energy market has undergone significant change in the past 12 months, with even more on the horizon. Our webinar series explores how these changes have shaped—and will continue to impact—the energy industry, including discussions of what's to come.

Our latest webinar featured FTI Consulting's Ken Ditzel, Senior Managing Director and Fengrong Li, Managing Director, who are both in the Economic and Financial Consulting Practice.

The carbon capture and sequestration tax credit under section 45Q is an important source of predictable revenue for carbon capture projects. The section 45Q credit was substantially expanded in 2018 and is worth up to $50 per metric ton for carbon permanently sequestered and up to $35 per metric ton for carbon used as a tertiary injectant in connection with an enhanced oil or natural gas recovery project.

Publisher: The National Law Review
Date: 5493B547C0AB527FF4CF8C4D0127302A
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did you hear about this:

Georgia's 2021 Sine Die - Thoughtful policy mixed with last minute surprises and everything
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IRS PLR: Post-Spin-Off Stock Repurchase Transaction Subject to Same Analysis as Otherwise Similar

For purposes of tax code Section 355(a)(1)(B) and regulations, a publicly traded corporation's ("Distributing") proposed transaction will be subject to the same analysis as an otherwise similar Distributing repurchase of its stock on the open market, the IRS ruled.

Twitter: @tax
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The Eleventh Circuit Court of Appeals: The Current Focus for Conservation Easements

Charitable conservation easements are currently one of the most litigated tax issues. Many of these easement cases are appealable to the U.S. Court of Appeals for the Eleventh Circuit, and that court is experiencing a mini-explosion of such cases. Nancy Ortmeyer Kuhn of Jackson & Campbell P.C. analyzes the breadcrumbs dropped by the 11th Circuit to date and opines as to a possible outcome based upon prior opinions from the Court.

Charitable conservation easements are currently one of the most litigated tax issues. Many of these easements are located in Georgia, Alabama and Florida. Therefore, we are now seeing a mini-explosion of cases appealed to the 11th Circuit Court of Appeals, with many more to follow. This article analyzes the breadcrumbs dropped by the 11th Circuit to date and opines as to a possible outcome based upon prior opinions from the Court. First a brief background of the issues.

Twitter: @tax
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IRS alleges Bristol Myers dodged $1.38B in taxes with offshore patent scheme: report |

Wall Street analyst Tim Anderson is known for asking tough questions during pharma companies' earnings calls, so it may not have seemed surprising when he brought up Bristol Myers Squibb's massive drop in its tax bill for 2012.

After all, the company paid an effective tax rate of negative 6.9% that year. Its tax rate the year before had been about 25%.

Anderson said during BMS' fourth-quarter earnings conference call in January 2013 that he recognized that all companies "optimize legal entities" to lower their tax rates. "Yet your rate is markedly lower than any other companies that I cover at least. And so I'm wondering why your tax rate might be unique in that regard," asked Anderson, who was then an analyst at Sanford C. Bernstein and has since moved to Wolfe Research.

Publisher: FiercePharma
Date: 2021-04-01T10:19:12-0400
Author: Arlene Weintraub
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