Political Quotes

“I rise today to engage in a colloquy with the distinguished chairman of the Senate Finance Committee, Senator Hatch. Mr. Chairman, I would like to clarify a point in connection with the application of the base erosion anti-abuse tax in the Tax Cuts and Jobs act to services companies. The act provides an exception from the base erosion anti-abuse tax for services. The act limits the exception to the ``total services cost with no markup.'' As a practical matter, companies account for amounts paid or accrued for services in a variety of ways. I would like to clarify that, if in a transaction a company used one account for services cost with no markup and another account for any additional amounts paid or accrued, that the first account would be subject to the exception under the bill. The act also excludes an amount paid or incurred for services if those services meet the requirements for the services cost method under Internal Revenue Code section 482, excluding the requirement that the services not contribute significantly to fundamental risks of business success or failure. Is it the intent that, for this purpose, that the business judgment rule under current law and regulations will not prevent an amount from being excluded under the act?”