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Business Cool On Obama's 2011 Budget,
by Mike Godfrey, Tax-News.com, Washington
Thursday, February 04, 2010
While President Barack Obama's proposals to cut tax and create additional investment
incentives for small business have been welcomed, representatives of America's
largest companies complain that other aspects of the 2011 budget proposals will
undermine the President's goals of accelerating the US economic recovery by
impeding their ability to invest internationally.
Commenting on Obama's 2011 budget plan, John J. Castellani, President of the
Business Roundtable, an association of chief executive officers of leading US
companies, warned that the President's proposals in the area of international
taxation in particular would damage US competitiveness and make it "virtually
impossible" for his target of doubling exports to be met.
“President Obama’s proposed budget undermines the goals he stated
in last week’s State of the Union address," Castellani stated. “The
President has argued that ‘the true engine of job creation in this country
will always be America's businesses.’ We couldn’t agree more. But
to create new and better-paying jobs, American companies must have the flexibility
to compete both here and abroad – where 95% of the world’s consumers
are."
Under proposals developed by the US Treasury Department, "excessive"
profits shifted offshore using transfers of intangible assets would be taxable
in the United States in an attempt to prevent firms from using transfer pricing
strategies to reduce liability to US tax. Along with a related proposal to clarify
the definition of intangible assets, this proposal would raise almost USD17bn
over the budget window.
The proposed transfer pricing reforms are part of a broader package of international
tax reforms that have been modified from last year's budget. The
proposal to deny companies an immediate deduction for deferred expenses remains broadly similar however.
Under current law, businesses that borrow money
and invest it overseas can claim the interest they pay as a business expense
and take an immediate deduction on their US taxes. This, business argues, gives US companies a vital advantage in the global market place.
The 2011 budget also includes restrictions to discourage businesses and individuals
to structure their affairs using offshore entities and accounts. The administration
claims that the full package of international proposals would raise USD122bn
over the budget window.
US Chamber Executive Vice President for Government Affairs R. Bruce Josten
said that the budget proposals, if enacted in their current form, would "dramatically increase taxes in a weak economy, and
undermine American job creation."
“This budget is a surefire way to slow economic growth, increase unemployment,
and make US companies less competitive around the globe," Josten stated.
“The US Chamber stands ready to support many of the job-creating proposals
outlined in the State of the Union Address," he continued. "However,
we cannot support a budget that will undermine the nation’s overriding
priority—creating jobs.”
A comprehensive report in our Intelligence Report series,
titled "Offshore For Corporates", discusses in depth the comparative
merits of offshore HQs, with a Corporate Treasury section analysing how to get
an optimal blend of tax-efficiency and profits and finally a study into how
two types of international business can use onshore low-tax regimes in parallel
with offshore jurisdictions to construct highly tax-efficient corporate structures,
is available in the Lowtax Library at http://www.lowtaxlibrary.com/asp/subs_reports.asp
and a description of the report can be seen at
http://www.lowtaxlibrary.com/asp/description_report7.asp
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