Legal Alert: Billionaires, BEAT, and Basis-Shifting – 2023 Green Book proposes tax changes affecting corporations, partnerships and individuals
Posted on Mar 31, 2022 in Legal Alerts
On March 28, 2022, the Biden Administration released the 2023 Fiscal Year Budget (the 2023 Budget). It is important to note that the Budget assumes the Build Back Better Act (the BBBA) will be enacted as passed by the House on November 19, 2021 (other than Section 137601 of the BBBA, which would increase the cap on the federal tax deduction for state and local income and real estate...
Treasury Green Book includes Pillar II undertaxed payments rule (UTPR), corporate tax increase rate
Posted on Mar 29, 2022 in International Tax, News
On March 28, the Biden Administration released the 2023 Fiscal Year Budget, followed by the release of the Treasury’s Green Book, which provides explanations of the Biden Administration’s revenue proposals. Among the proposals is the adoption of the OECD’s Pillar II undertaxed payments rule (UTPR) in lieu of the Base Erosion Anti-Abuse Tax (BEAT). The UTPR denies a deduction or...