Your Perspective Matters: Complete Our Family Business Survey
Congressional Lawmakers Hold Leadership Elections: On Nov. 13, the Senate and House Republican conferences held their leadership elections. Sen. John Thune (R-SD), the current Republican whip, was elected as the Senate majority leader for the 119th Congress, defeating Sens. John Cornyn (R-TX) and Rick Scott (R-FL). Sen. John Barrasso (R-WY) ran unopposed for majority whip, and Sen. Tom Cotton (R-AR) defeated Sen. Joni Ernst (R-IA) to serve as chairman of the Senate Republican Conference.
Republicans to Scrutinize Energy-Tax Credits with Trifecta: As Republicans head into January with control over the presidency and both chambers of Congress, discussion over what to include in a tax package will invariably delve into whether to repeal some of the energy-tax credits in the Inflation Reduction Act (IRA, Pub. L. 117-169) and CHIPS and Science Act (Pub. L. 117-167). Prior to the election, Republican leaders signaled that they would closely scrutinize these credits but would not rush to full repeal. For example, House Speaker Mike Johnson (R-LA) signaled disapproval of many of the IRA’s credits but left the door open to retaining some of them, preferring to use a ”scalpel and not a sledgehammer” in analyzing each credit.
Trump’s Win Puts Increased Scrutiny Over OECD Two-Pillar Deal: When President-elect Trump takes office in January, his administration will face a decision over whether to continue the Biden administration’s ongoing negotiations within the Organisation for Economic Co-operation and Development (OECD) over its proposed two-pillar international tax framework. Tax-policy experts have indicated that Pillar Two, which includes an undertaxed profits rule (UTPR) to tax international corporate revenue at a minimum rate of 15%, is “in peril” due to the potential for a Trump administration to retaliate against countries with steep tariffs on imports should they impose a UTPR on U.S. companies. However, other experts contend that, while the Trump administration is expected to take a “more aggressive posture” towards protecting the U.S. tax base, renegotiation may be the preferred route due to concerns among members of Congress.
Biden Administration Temporarily Backs Off from Challenging Canada’s DST: On Nov. 14, a spokesperson for the United States Trade Representative (USTR) indicated that the Biden administration was not planning to challenge Canada’s digital services tax (DST) under the terms of the United States-Mexico-Canada Agreement (USMCA), after initially seeking consultation with Canada over the issue on Aug. 30. That consultation request included a 75-day period for the Biden administration to consider requesting a dispute panel should consultations fail. The spokesperson said that consultations with Canada continue and that the USTR “reserve [its] rights to further proceedings, including under the USMCA, should those concerns not be resolved.”
IRS Issues Final Regulations on Repatriation of Intangible Property: On Oct. 9, the Internal Revenue Service (IRS) issued final regulations on the transfer of intangible property, such as patents and trademarks, from foreign corporations to U.S.-based persons. The regulations provide guidance on the repatriation process, including when the U.S.-based person would recognize gain of the intangible property and when annual income inclusions for the useful life of the intangible property, governed under Section 367(d) of the tax code, should terminate. The regulations make minor refinements to proposed regulations issued in May 2023.
About Brownstein Hyatt Farber Schreck
Brownstein Hyatt Farber Schreck is a unique law firm. Walk into any of our offices and you’ll immediately recognize a different type of energy. Complacency doesn’t have a place here. Flexibility and inspiration do. Our culture and enthusiasm allow our attorneys, policy consultants and legal staff to stay ahead of our clients’ needs and provide them with the resources they require to meet their business objectives.
We hope you've enjoyed this article. While you're here, we have a small favor to ask...
As we prepare for what promises to be a pivotal year for America, we're asking you to consider becoming a member.
The need for fact-based reporting of issues important to multi generational businesses and protecting a lifetime of savings has never been greater. Now more than ever, multi generational businesses and family businesses are under fire. That's why Family Enterprise USA is passionately working to increase the awareness of issues important to generationally-owned family businesses built on hard work, while continuing to strengthen our presence on Capitol Hill. The issues we fight for or against with Congress in Washington DC include high income tax rates, possible elimination of valuation discounts, increase in capital gains tax, enactment of a wealth tax, and the continued burden of the gift tax, estate tax and generation skipping tax.
Family Enterprise USA promotes generationally owned family business creation, growth, viability, and sustainability by advocating for family businesses and their lifetime of savings with Congress in Washington DC. Since 2007, Family Enterprise USA has represented and celebrated all sizes, professions and industries of family-owned enterprises and multi-generational employers. It is a bi-partisan 501.c3 organization. Family foundations can donate.
#incometax #taxseason #federaltaxpolicy #taxation #EstateTax #Deathtax #wealthtax #taxLegislation #CongressionalCaucus #CapitalGainsTax #incometaxrates #incometaxseason #taxrefund #taxreturn #incometaxreturn #gifttax #Generationskippingtax #InheritanceTax #repealestatetax #FamilyBusiness #promotefamilybusinesses #familyowned #supportlocalbusiness #womeninbusiness #AdvocatingForFamilyBusinesses #Generationallyowned #Multigenerationalbusiness @FamilyEnterpriseUSA @PolicyAndTaxationGroup @DitchTheEstateTax #FamilyEnterpriseUSA #PolicyAndTaxationGroup #DitchTheEstateTax