Overview
Lawmakers Ask Treasury to Withdraw a Portion of Proposed Regulations for Section 199 Deduction:On July 25, Representatives Patrick Tiberi (R-OH) and Richard Neal (D-MA) and Senators Rob Portman (R-OH), Debbie Stabenow (D-MI), and Sherrod Brown (D-OH) wrote a letter to Treasury Secretary Steven Mnuchin urging that the portion of proposed Treasury Regulation REG-136459-09) eliminating the benefits and burdens test be withdrawn. The letter discusses recently introduced legislation, bills H.R. 1296 and S.638, which the letter states are intended to clarify the intent of section 199 in contract manufacturing situations to allow any party to the arrangement to take a deduction based on its own income from the domestic goods. The letter then requests that Treasury take action going forward to ensure that “the IRS consistently applies the section 199 regulations to allow taxpayers to claim the DPA deduction regardless of whether they manufacture through vertically integrated or non-vertically integrated supply chains so long as they substantially contribute to the manufacture of goods produced in the U.S.”
Senators Propose Bill to Provide Tax Credits for Offshore Wind Facilities:Yesterday, Senators Tom Carper (D-DE) and Susan Collins (R-ME) introduced the Incentivizing Offshore Wind Power Act, which would provide tax credits for the first 3,000 megawatts of offshore wind facilities put into service. Senator Carper stated that “[o]ffshore wind energy has the potential to power every home, school and business from Florida to Maine with clean, renewable energy.”
Platform for Collaboration on Tax Seeks Feedback on Draft Toolkit on the Taxation of Offshore Indirect Transfers of Assets:The Platform for Collaboration on Tax, a joint initiative of the International Monetary Fund (IMF), Organization for Economic Cooperation and Development (OECD), UN, and World Bank Group put together a draft toolkit “designed to help developing countries tackle complexities of taxing offshore indirect transfers of assets.” The Platform seeks comments from the public by September 25.