MANAGEMENT | TAX PLANNING
When Congress returns following the November elections, the issue of what to do about US companies making foreign acquisitions to relocate overseas and save on taxes will be high on the agenda. The solution, if crafted properly, could induce General Electric, Microsoft, Pfizer and others to repatriate some of the $2.1 trillion of untaxed foreign profits they hold overseas, giving a boost to the US economy.
The Treasury Department’s recent crackdown on corporate inversions makes it tougher for US companies to access their overseas cash stockpiles without paying US tax. The new rules also make it harder to meet strict requirements for an inversion.
Oregon’s Ron Wyden, the Senate’s top Democratic tax writer, says: “Congress should move a bipartisan bill in the lame-duck session as an immediate action to address inversions, to create incentives so businesses will remain in or move to the US, and to use that legislation as a springboard to comprehensive tax reform.” Wyden and Republican Orrin Hatch of Utah, ranking member of the Senate Finance Committee, both said they are committed “to developing a stopgap measure that will garner support from both sides of the aisle.”
While the lame-duck Congress is unlikely to reach a wide-ranging agreement, it could decide to tax only the domestic profits of companies. This would put the US system more in line with global norms and encourage repatriation of foreign earnings.
Ahead of the September G20 meeting, the OECD released recommendations for a single set of international tax rules that could force multinationals to disclose where they make their profits and pay taxes on a country-by-country basis. Analysts say progress will be glacial on a global standard, however. It is impressive, nonetheless, when 44 countries representing 90% of the world’s economy agree on anything.
