Key Takeaways
- Trump Picks
- Legislation
- TCJA
- Energy Credits
- IRS
- Louisiana
- Transfer Pricing
- In the Courts
- Blasé Parfait
Trump Picks
Trump Taps Bessent for Treasury Secretary – Benjamin Valdez and Alexander Rifaat, Tax Notes ($):
Bessent is the CEO of investment firm Key Square Group and served as an economic adviser for Trump during his re-election campaign.
In a statement November 22, Trump touted Bessent’s decades-long experience on Wall Street as a key factor in his decision.
Trump Taps Hedge Fund Billionaire Bessent to Head Treasury – Hailey Konnath, Law 360 ($):
In a statement, Trump said Bessent "will help me usher in a new Golden Age for the United States as we fortify our position as the world's leading economy, center of innovation and entrepreneurialism [and] destination for capital."
Treasury Pick Bessent Tells WSJ That Trump Tax Cuts Are Priority – Philip Glamann, Bloomberg:
Putting tariffs in place and reducing spending will also be a focus, Bessent said, though he didn’t go into detail, according to the newspaper’s report. Trump has threatened to hit Chinese shipments with tariffs of 60%.
Trump’s Treasury Pick Wants Shadow Fed Chair, Maybe Weak Dollar – Jarrell Dillard and Stephanie Lai, Bloomberg ($):
If confirmed by the Senate, he will have a sprawling remit: oversee public financing, economic sanctions and the Internal Revenue Service; engage in international economic diplomacy; and help ensure the smooth functioning of financial markets. Bessent, who currently runs macro hedge fund Key Square Group LP, will be crucial to implementing the president-elect’s agenda, which includes renewing some of Trump’s 2017 tax cuts that expire next year and loosening financial regulations.
Project 2025 Goes from Pariah to Pipeline as Trump Staffs Up – Eric Martin, Bloomberg ($). “As a candidate, Donald Trump disavowed the MAGA manifesto Project 2025, calling its ideas “abysmal.” Now the president-elect has nominated or appointed to his incoming administration at least five people involved in the project.”
Legislation
GOP Plans Roadmap for Renewing 2017 Tax Law in First 100 Days – Zach C. Cohen, Bloomberg ($):
Unlike most legislation in the narrowly divided federal legislature, simple majorities will be able to move that bill thanks to a process known as budget reconciliation.
Republicans’ Big Tax Challenge Is Fitting All Their Priorities in One Bill – Richard Rubin, Wall Street Journal:
Engineering the legislation that way can help the party completely sideline Democrats, and it is Republicans’ best chance to quickly exploit unified control of the House, Senate and White House. Strike first, strike hard, no mercy, to borrow an ’80s movie catchphrase.
Republicans Ponder: What if the Trump Tax Cuts Cost Nothing? – Andrew Duehren, New York Times:
That is the question on the minds of many Republicans on Capitol Hill these days as they consider how far — and how fast — they can cut taxes again. The wonky ways of measuring the federal budget are shaping up to be central to the debate.
Forcing the issue is the end of many of the tax cuts Republicans passed in 2017. Without any action by Congress next year, taxes would go up for most Americans, as provisions like lower marginal income rates and a larger standard deduction expired. Republicans want to protect their handiwork and extend the tax cuts before they lapse.
Taiwan Caucus Seeks Lawmaker Buy-in on Stalled Tax Legislation – Chris Cioffi, Bloomberg ($):
The bipartisan tax legislation would provide treaty-like benefits to relieve double taxation on companies doing business between the US and Taiwan without angering Beijing, which claims the island democracy as part of China. The tax legislation was included in the $78 billion bipartisan legislation negotiated by Senate Finance Chair Ron Wyden (D-Ore.) and House Ways and Means Chair Jason Smith (R-Mo.) that passed the House but failed to advance in the Senate.
TCJA
Manufacturers Push for Preservation of TCJA International Rates – Andrew Velarde, Tax Notes ($). “The National Association of Manufacturers is calling on Congress to stop the scheduled taxpayer-adverse adjustments to rates for key international tax provisions of the Tax Cuts and Jobs Act set to take effect after 2025.”
Energy Credits
Newsom Challenges Trump on Electric Vehicle Tax Credits – Lisa Friedman, Soumya Karlamangla, and Shawn Hubler, New York Times:
“We will intervene if the Trump administration eliminates the federal tax credit, doubling down on our commitment to clean air and green jobs in California,” Mr. Newsom, a Democrat, said in a statement. “We’re not turning back on a clean transportation future — we’re going to make it more affordable for people to drive vehicles that don’t pollute.”
Mr. Newsom’s proposal comes as California officials gird for an extended battle with the incoming Trump administration over environmental policy, immigration and other issues. As he did during his first term, Mr. Trump is expected to try once again to block California’s authority to set auto emissions limits that are stricter than federal standards.
How Trump Could Upend Electric Car Sales – Lawrence Ulrich, New York Times. “Many car buyers have come to rely on a $7,500 federal tax credit on electric vehicles to soften the blow of their high prices. But those credits could disappear after President-elect Donald J. Trump takes office, leading to an almost immediate drop in sales of the cars and trucks.”
Energy Credit Elective Pay Shows Increasing Take Rate – Caitlin Mullaney, Tax Notes ($). “A Treasury official touted the success of the online preregistration process for applicable entities to elect the direct-pay option for clean energy credits, known as elective pay, while acknowledging some growing pains.”
IRS Extends Period to Avoid Clean Energy Payment Phaseout – Mary Katherine Browne, Tax Notes ($):
IRS Notice 2024-84, 2024-50 IRB 1, issued November 22, extends the transition process for claiming a statutory exception to phaseouts of elective payments for applicable credit properties with construction beginning before January 1, 2027, or the issuance of further guidance.
IRS Extends Domestic Content Relief for Energy Credits – Kat Lucero, Law 360 ($). “Nonprofits, tribal governments, public utilities and other tax-exempt groups eligible for a direct cash payment of their clean energy tax credits can get relief from meeting the domestic content requirements tied to those incentives for 2025 and 2026 under IRS guidance released Friday.”
IRS
IRS Working to Incorporate Feedback on Donor Fund Regs – Kat Lucero, Law 360 ($):
Nonprofits, businesses and other stakeholders have raised major issues with the proposed rules in the past year, including with their definition of donor-advised funds, exceptions from the excise tax and effective dates, according to Randall Thomas, special counsel at the agency's exempt organization division.
Preapproved Benefit Plan Opinion Letters Coming Soon, IRS Says – Mary Katherine Browne, Tax Notes ($). “The IRS will soon begin issuing opinion letters in response to applications filed with the agency for the second remedial amendment cycle for preapproved section 403(b) defined benefit plans.”
IRS Debuts Form for Electing Inclusion of Unvested Property – Kristen A. Parillo, Tax Notes ($):
Taxpayers can now use Form 15620, “Section 83(b) Election,” posted on the IRS website November 7, to make a section 83(b) election instead of having to create their own election forms using sample language provided in Rev. Proc. 2012-29, 2012-28 IRB 49.
Louisiana
Louisiana lawmakers pass income and corporate tax cuts, raising statewide sales tax to pay for it – Jack Brook, Washington Post:
The final passage of the tax measures wrapped up a special legislative session launched Nov. 6 by the governor and his allies. They said their purpose was to make the state’s tax code more business friendly, create jobs and reverse trends of outward migration from the state. It was the third special legislative session called by Landry, a Republican, since he assumed office in January.
Transfer Pricing
Amgen Denies Misleading Investors About Transfer Pricing Risks – Amanda Athanasiou, Tax Notes ($). “Amgen Inc. and two of its executives have denied allegations that the company improperly concealed the scope of its potential tax exposure in connection with its transfer pricing dispute with the IRS.”
In the Courts
High Court to Review Legality of FCC's Subsidy Fees – Christopher Cole, Law 360 ($). “The U.S. Supreme Court agreed Friday to review whether fees collected to support the Federal Communications Commission's array of telecom subsidy programs for low-income consumers, schools and rural healthcare run afoul of constitutional limits on taxing authority.”
IRS Ignores Text In $248M Fight, Liberty Global Tells 10th Circ. – Natalie Olivo, Law 360 ($). “The Internal Revenue Service is incorrectly applying the U.S. tax code in denying Liberty Global's claim for $248 million in foreign tax credits tied to its sale of a Japanese affiliate, the telecommunications company told the Tenth Circuit.”
Halliburton Omitted Grounds From $35M Refund Suit, US Says – David Hansen, Law 360. ($). “A Texas federal court must dismiss parts of Halliburton's $35 million tax refund lawsuit because the company failed to raise two grounds of relief in its administrative claim for a refund, the U.S. argued.”
Vitamin Co. Must Freeze Owner Payouts Amid $1.4M Tax Fight – Anna Scott Farrell, Law 360 ($). “A Connecticut federal judge has granted the federal government a temporary restraining order in a $1.4 million tax fight with a vitamin company, barring distributions to the owners unless the company allocates 20% to the court's registry to help cover the potential liability.”
What Day is it?
Its kind of meh on this annual Blasé Day. But if you prefer, celebrate National Parfait Day instead!
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