Overview
Treasury, IRS Extend Deadline for Filing Basis Consistency Statement: Today, the Treasury Department and the IRS issued Notice 2016-19, extending the deadline for statements reporting estate basis consistency from February 29 to March 31. The notice states that proposed regulations will be issued shortly addressing the requirements of section 6035, and that executors and other persons required to file a return under section 6018 should wait for the issuance of the proposed regulations to prepare the statements required by section 6035(a)(1) and (a)(2).
DTU IN DEPTH
President Obama's Final Budget Proposal Renews Call for Comprehensive International Tax Reform, Echoes Administration's Prior Proposal: On February 9, 2016, the Obama Administration (Administration) released its Budget of the United States Government, Fiscal Year 2017. In conjunction with the release of the Administration’s budget proposal, the US Department of the Treasury also issued its General Explanations of the Administration’s FY2017 Revenue Proposals (the Greenbook).
In sum, the Administration’s international tax proposals do not break new ground. In fact, all of the proposals appeared in the Administration’s budget for FY 2016 (2016 budget). The only differences are revised proposed effective dates, revenue expectations, and changes to reflect the permanent extension of the exception under subpart F for active financing income and the temporary extension of the look-through treatment of payments between related controlled foreign corporations (CFCs). Although the proposals have generally not been embraced by members of Congress, they remain relevant as markers in fundamental tax reform discussions and as potential revenue raisers outside of tax reform. For more in-depth coverage, click here.