Daily Tax Update - April 14, 2015: Sanders Introduces Bill Repealing Defferal

Sanders Introduces Bill Repealing Deferral:  Today, Senator Bernie Sanders (I-VT) introduced the “Corporate Tax Dodging Prevention Act of 2015.”  The legislation would (1) tax U.S. corporations on all of their foreign profits; (2) further limit the ability of foreign-owned U.S. affiliates to deduct interest expense; (3) treat foreign corporations managed and controlled in the United States as U.S. corporations; (4) modify the section 7874 inversion rules to treat inverted companies as U.S. companies if they are majority-owned by the pre-inversion U.S. company’s owners; (5) impose a per-country foreign tax credit limitation; and (6) limit the creditability of certain amounts paid by oil companies that are dual capacity taxpayers. 

Miscellaneous Guidance:
Notice 2015-33 provides adjusted limitations on housing expenses for tax year 2015 for purposes of the foreign earned income exclusion and foreign housing exclusion.