The chairman of the US Senate Finance Committee, Max Baucus (D) has published some proposals for reform of international aspects of the US tax code. There is lots to read here.
One could look for possible implications for Ireland through the references to foreign income, Subpart F, “check the box”, the “same country exemption”, the CFC “look-through rule”, inversions or section 482 (transfer pricing) and other provisions in the US tax code that we have heard about but don’t fully understand. However, there are lots of reasons why this set of proposals may not get very far. Trying to find a word of support in the statement from the chairman of the House Ways and Means Committee, Dave Camp (R) is one and the impending retirement of Baucus in 2014 is another. The point is simply that the debate is not standing still even if actual reform still appears to be a way off.
Here is a report from Bloomberg on the proposals.