Overview
Law360 quoted George Callas in a January 27 article titled "High-Tax Exception to TCJA Rule Catching Political Heat." The article discusses how a regulatory tweak to the international framework of the 2017 tax overhaul, little known outside the tax world, has erupted into a political firestorm as critics claim it amounts to a corporate giveaway from the US Treasury Department. Treasury's proposed rules allow companies to opt into it, even though none of the language mentions optionality for taxpayers.
Callas, senior tax counsel to then-House Speaker Paul Ryan during the Tax Cuts and Jobs Act (TCJA) passage, says: "My reading is that it is ambiguous, and there are two reasonable readings of the statute, and Treasury has the authority to pick a reading. They chose the one that's the more reasonable reading, based on congressional intent."
The full article can be read at Law360 (subscription required).