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Going “Green”: The call to reform – the US Green Book

The Tax Specialist | 1 Feb 10
 
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Published on 01 Feb 10 by "THE TAX SPECIALIST" JOURNAL ARTICLE

There has been a raft of proposals to reform the US international tax laws and improve their enforcement. Some of the more sensational proposals include the removal of the “check-the-box” election, the determination of deemed paid foreign tax credits on a consolidated basis for all foreign taxes paid by foreign subsidiaries and the repeal of the “80/20” corporation provisions. The impact of these changes is still unclear; however US corporations should be considering the potential impact of these changes now in the event these proposals become law.

Author profile

Neil Pereira CTA
Neil is a Tax and Legal Partner with more than 20 years of international tax advisory and structuring experience for multinational clients across a range of industries. Neil’s extensive experience includes leading multidisciplinary teams on tax planning and due diligence for corporate reorganisations, legal entity reduction and consolidation of Australian operations for tax and broader business model and supply chain optimisation. Neil has advised clients on the Australian tax and legal implications of setting up business structures, share and business transfers, IP migration, foreign investment review board as well as regulatory and tax compliance for multinational groups. - Current at 25 July 2022
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