today Mr. Mack and I are again introducing legislation to place a permanent moratorium on the Department of the Treasury's authority to finalize any proposed regulations issued pursuant to Notice 98-35, dealing with the treatment of hybrid branch transactions under subpart F of the Internal Revenue Code. Our bill also prohibits Treasury from issuing new regulations relating to the tax treatment of hybrid transactions under subpart F and requires the Secretary to conduct a study of the tax treatment of hybrid transactions and to provide a written report to the Senate Committee on Finance and the House Committee on Ways and Means. By way of background, the United States generally subjects U.S. citizens and corporations to current taxation on their worldwide income. Two important devices mitigate or eliminate double taxation of income earned from foreign sources.
John B. Breaux: “today Mr. Mack and I are again introducing legislation to place a permanent moratorium on the Department of the…”
Editor's note · Context
Introducing legislation to impose a moratorium on Treasury regulations regarding hybrid branch transactions.
Share
More from John B. Breaux
Senator Landrieu and I rise today to add our voices to those who have been calling for a comprehensive national solution to the asbestos litigation problem. Several members of both parties have recently come to the floor to discuss this…
I rise today to honor the veterans of the U.S. Armed Services and to thank those who continue to serve bravely and protect the United States around the world. My home State of Louisiana has made a significant contribution to the war on…
I close on this amendment with the following comments: In this legislation, we are giving U.S. companies that hire foreign workers in foreign countries and putting their money that they earned in tax savings the opportunity, the gift, to…
I start off by commending the authors of the amendment for a real serious effort to try to improve the bill. But I rise in opposition because there is not any segment of the senior population that you could not isolate and target and say…