Home/Tag: corporate integration

S-Corp on Section 385

The S Corporation Association has sent a letter to the two congressional tax committees asking them to support efforts to pull Treasury’s proposed section 385 regulations released back on April 4th.  The comment period for these regs doesn’t close until July 7th, and we intend to submit lengthy comments outlining our numerous concerns with the regulations and how they will hurt Main Street businesses.

But in the meantime, we believe it is important for policymakers to have a better sense of just how far these regulations extend and the costs they will impose on businesses of all stripes operating in

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2019-02-01T19:56:24+00:00May 25, 2016|

Senate Finance Hearing on Corporate Integration

Remember the pass-through mantra for tax reform?  All business income should be taxed once, it should be taxed at the same top rate, and then we should leave it alone!  Well, that mantra was on display Tuesday when a panel of tax experts explored the benefits and costs of corporate integration.  Here’s Dr. Michael Graetz:

 “In the 1990s, principally because of its administrative advantages, the Treasury Department recommended taxing business income once—at the business level. This form of integration was advanced by President George W. Bush in 2003, but Congress instead simply lowered shareholders’ income tax rates on dividends.  That

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2019-02-01T19:56:24+00:00May 19, 2016|

Rate Parity Bill Introduced!

For five years, the S Corporation Association and its allies have asked tax writers to pursue business tax reform that taxes all business income just once and at the same, reasonable top rates.  That’s the correct way to tax business income and more than 100 trade groups, including the largest trade groups in the country representing millions of employers, have signed on to this premise.

And for five years, we’ve watched as the tax code moved in exactly the opposite direction.

Instead of preserving rate parity, the combination of the Fiscal Cliff and the implementation of the Affordable Care Act resulted in

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2019-02-01T19:56:25+00:00April 29, 2016|

More on Corporate Integration

Lots of chatter on corporate tax reform last week.  First, Finance Committee Chair Orrin Hatch gave a speech on the Senate floor making clear that only comprehensive changes to our tax code would help to make our tax treatment of business income more internationally competitive and end the ongoing exodus of US companies to foreign tax jurisdictions.

Well, at the same time, most of the proposals we’ve seen to deal with inversions would amount to building a virtual wall – a wall forged in regulation and punitive tax treatment – around the country to keep companies from leaving and making

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2019-02-01T19:56:25+00:00April 25, 2016|

S-Corp in WSJ

S-Corp President Brian Reardon and Advisory Committee Chair Tom Nichols made the pass-through tax reform case in the pages of the Wall Street Journal on Friday.

The core message of the piece is that businesses both large and small have already voted against the concept of double-taxing business income, and it’s time for the tax code to catch up.  As the piece notes:

On paper, the U.S. has a world-wide tax system that imposes two layers of tax on overseas business income—an initial foreign tax when the money is earned and a second U.S. tax when the money is repatriated. In

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2019-02-01T19:56:25+00:00March 1, 2016|