Political Quotes

“I thank the ranking member of the Senate Finance Committee for his work on getting bipartisan agreement on this declaration. This declaration is necessary, given the reservation amending article 23. The reservation regarding article 23 amends language addressing the scope of double tax relief in connection with income earned by a Chilean subsidiary of a U.S. company. That reservation, which was initiated by the current Treasury Department, calls into question whether article 23 provides sufficient relief for double taxation; specifically, in the case of a U.S. company owning at least 10 percent of a Chilean company, whether the U.S. would provide a credit under the treaty for income taxes paid or accrued to Chile by or on behalf of that U.S. company with respect to earnings that were also subject to U.S. tax under the global intangible low-taxed income, or GILTI, provision enacted in the Tax Cuts and Jobs Act, or TCJA. Although the Treasury Department did not agree to include a specific clarification in the reservation with respect to that question, the declaration in the resolution confirms that Treasury acknowledges that, in light of TCJA's substantial changes to the international provisions of our Tax Code, additional work is needed to evaluate the policy of article 23 and whether it is sufficient in addressing relief from double taxation.…”