Tax reform is an important opportunity to make the U.S. significantly more competitive for all types of business investment, including vital foreign direct investment (FDI). U.S. subsidiaries of global companies generate precisely the types of high-value jobs and economic activities that should be encouraged through fundamental tax reform.
OFII strongly supports a significant reduction in the U.S. corporate income tax rate, elimination of unnecessary complexity and administrative burden, and establishment of a more transparent tax code that will provide the certainty businesses need to grow in the United States. These efforts must be carried out in a non-discriminatory manner that encourages global investment in the U.S. economy.
In April, the U.S. Department of Treasury proposed regulations touted as an effort to curb so-called "inversions." Proposals made under Section 385, however, go far beyond that purpose and would impose sweeping changes to how debt and equity are classified -- upending decades of case law, instituting subjective standards, and creating an unpredictable environment for multinational companies operating in the United States.
OFII Comment Letter to Treasury Department on the proposed regulations issued under IRC Sec. 385, July 2016
OFII, BRT, and PwC Analysis of IRC Sec. 385 proposed regulations, July 2016
OFII Coalition Letter to Chairman Brady, Chairman Hatch, Ranking Member Levin, and Ranking Member Wyden regarding IRC Sec. 385 proposed regulations, June 2016
OFII Coalition Letter to Secretary Lew regarding IRC Sec. 385 proposed regulations, May 2016
OFII Comment Letter to Ways and Means Committee on "The Global Tax Environment," February 2016
OFII Comment Letter to Treasury Department on the revised U.S. Model Tax Convention, September 2015
OFII Comment Letter to Senate Permanent Subcommittee on Investigations on "Market for Corporate Control and Jobs," July 2015
OFII Comment Letter to Senate Finance Committee Tax Reform Working Group, April 2015
OFII Comment Letter to Ways and Means Committee on "Moving America Forward", January 2015
OFII Letter to IRS on Notice 2014-52 with repsect to Foreign Insurance Companies, December 2014
OFII Letter to House Appropriations Committee on Contract Bans, October 2014
Trade Association Letter on Inversions to Senate Finance Committee, October 2014
OFII Letter to Chairman Wyden on July 22 Finance Committee Hearing, August 2014
OFII Letter to Chairman Baucus on International Tax Reform Discussion Draft, January 2014