Administration Issues General Explanation Of Its Fiscal Year 2010 Revenue Proposals, Including International Provisions

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Administration Issues General Explanation Of Its Fiscal Year 2010 Revenue Proposals, Including International Provisions

On May 11, the Obama Administration (the

"Administration") issued general explanations of its

Fiscal Year 2010 revenue proposals, including a number of

international tax reform proposals that could have a dramatic

impact on multinational businesses and other taxpayers with foreign

investments or activities. The proposals provide a more

comprehensive look at international tax proposals that had

previously been described, including proposals to impose

significant constraints on the ability to defer U.S. tax on foreign

earnings, tighten limitations on claiming foreign tax credits, and

create a wide array of enhanced compliance measures. The

Administration also introduced various new international tax

proposals.

The following is a summary of the Administration's

international tax proposals. Except as noted below, the proposed

changes to the substantive tax rules would be effective for tax

years beginning after December 31, 2010, while the effective dates

for the various enhanced compliance measures generally depend upon

the date of enactment.

Limit "Check-the-Box" Rules

Expressing concern that check-the-box elections have been use...

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