NYSBA Section Questions Bill to Reduce Foreign Multinationals' Benefits

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The New York State Bar Association Tax Section urges caution—and perhaps reconsideration—in proceeding with legislation (H.R. 62) that would sharply reduce U.S. tax benefits for foreign multinational corporations by treating them as domestic corporations for tax purposes if they are primarily managed and controlled in the United States. In a letter to lawmakers and government officials accompanying a 51-page report, the tax section said it is also concerned by specific language in the bill that would curtail benefits for investment entities, such as hedge funds, securitization vehicles, and other pooled investment funds with U.S. sponsors.