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Proposed Tax Bills Released by House Republicans

June 23, 2023

House Republicans Propose Tax Bills
House Republicans released a set of proposed tax bills, which include reviving full bonus depreciation and interest expense deduction under Section 163(j). The bill includes the expansion of opportunity zones, among other changes. A provision in the new tax proposal would allow companies to partly disregard Treasury Department rules on the foreign tax credit that has been the target of complaints. The bills also would repeal some provisions of the tax and climate bill of the Democrats.

Treasury and IRS Propose Rules on Monetizing Energy Tax Credits
The IRS and Treasury Department proposed rules on monetizing clean energy tax credits. The Inflation Reduction Act outlined alternatives for taxpayers who want to buy or sell their energy tax credits instead of using tax equity investment structures. The law allows tax-exempt and government entities to receive a refundable payment instead of a credit. The new rules further define how to register for the credit and who is eligible to receive it.

Liberty Global Argues It Didn’t Underpay Tax in 2018 Transaction
Liberty Global, a telecommunications giant, argued that it did not owe $284 million in taxes with respect to a series of transactions in 2018. The company, responding to a Department of Justice (DOJ) lawsuit seeking $237 million in taxes and $47 million in related penalties, claimed that the company engaged with a professional accounting firm over a series of transactions as a tax adviser. DOJ claimed that the accounting firm approached the company about an opportunity to exploit a perceived loophole in the international provisions of the 2017 tax law. The taxes at issue were tied to Section 245A, which provides a tax deduction for certain dividends received from foreign corporations.

Information contained in this publication should not be construed as legal advice or opinion or as a substitute for the advice of counsel. The articles by these authors may have first appeared in other publications. The content provided is for educational and informational purposes for the use of clients and others who may be interested in the subject matter. We recommend that readers seek specific advice from counsel about particular matters of interest.

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