UF Tax Incubator: Complexities, Discontinuities, and Unintended Consequences of US International Tax Rules: Options for Change (American Enterprise Institute Symposium (June 17-18, 2024):

• Forward (p. 1)
• Potential Changes to Section 367 and the Associated Treasury Regulations (p. 11)
• Considerations for Reforming the U.S. Source of Income Rules (p. 27)
• U.S. Subsidiaries of Foreign-Based MNEs — BEAT and Section 163 (p. 43)
• Considerations Relating to CFC Stock Ownership and Allocation of Subpart F Income (p. 65)
• Taxation of Foreign Branches (p. 73)
• Considerations for Reforming the U.S. Transfer Pricing Rules (p. 91)
• U.S. Ownership of Foreign Stock: Dividends and Gains on Sale (p. 111)
• Taxation of Foreign-Derived Intangible Income (p. 127)
• Subpart F and GILTI Recommendations (p. 145)
• Taxation of Foreign Income Earned by Individuals and Minority Shareholders of Passive Foreign Corporations (p. 161)
• FTC Proposals, Part I: Creditable Foreign Taxes (p. 179)
• FTC Proposals, Part II: TCJA White Paper (p. 201)

The UF Tax Incubator consists of Executive Director Mindy Herzfeld, professor of tax practice at the University of Florida Levin College of Law; steering committee members Paul Oosterhuis, of counsel at Skadden, Arps, Slate Meagher & Flom LLP; Pat Brown, principal at PwC; Kim Blanchard, Law Offices of Kimberly Blanchard PC; Pam Olson, consultant at PwC; Eric Solomon, partner at Ivins, Phillips & Barker Chtd.; and Lowell Yoder, partner at McDermott Will & Emery; and working group members: Nita Asher, principal at PwC; Michael Caballero, partner at Covington & Burling LLP; Harrison Cohen, managing director at Deloitte; Ron Dabrowski, principal with KPMG LLP’s Washington National Tax practice; Rocco Femia, member at Miller & Chevalier Chtd.; Kara Mungovan, partner at Davis Polk & Wardwell LLP; Jose Murillo, partner at EY; David Noren, partner at McDermott Will & Emery; Amanda Pedvin Varma, partner at Steptoe; Joshua Ruland, principal at EY; and Eric Sensenbrenner, partner at Skadden; with the additional assistance of Noha Nayeri, director at PwC; Caitlin Hird, an attorney at Skadden; Eman Cuyler, associate at Skadden; and Monica Zubler, KPMG.

The symposium papers include contributions from Nita Asher, Kim Blanchard, Pat Brown, Michael Caballero, Harrison Cohen, Eman Cuyler, Ron Dabrowski, Rocco Femia, Mindy Herzfeld, Caitlin Hird, Kara Mungovan, Jose Murillo, Noha Nayeri, Paul Oosterhuis, David Noren, Joshua Ruland, Eric Sensenbrenner, Amanda Pedvin Varma, and Monica Zubler.

Editor’s Note:  If you would like to receive a daily email with links to tax posts on TaxProf Blog, email me here.