Financier Worldwide 2016 Global Tax Annual Review – United States

With an ever-changing and increasingly complex global tax landscape, Financier Worldwide canvassed the opinions of leading professionals around the world on the latest trends in global tax.  Caplin & Drysdale’s Peter A. Barnes offers his insights, from a U.S. perspective, in Financier Worldwide’s 2016 Global Tax Annual Review.  Please contact marketing@capdale.com to access the full report.

Excerpt taken from the report.

“Gridlock in Congress prevented any major tax legislation from being enacted over the past year, but important developments emerged in regulations and court decisions. Most notably, new regulations severely restrict the ability of US companies to ‘invert’ in a tax-efficient manner and thereby shift their ownership to a foreign parent. Proposed regulations also include sweeping changes to the rules for classifying an instrument as debt or equity, with the result of limiting US companies’ ability to pay interest to foreign parents. The controversial Altera court decision overturned US regulations on cost-sharing agreements with respect to how taxpayers must treat stock options in such agreements.”