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Extraction Summary

1
People
2
Organizations
2
Locations
2
Events
0
Relationships
3
Quotes

Document Information

Type: Legal analysis / tax policy memorandum / house oversight record
File Size: 1.64 MB
Summary

This document is a page from a legal or tax policy analysis, likely part of House Oversight records. It details the 'Obama Proposal' within the 2010 budget, which aimed to alter 'check-the-box' regulations to treat certain foreign subsidiaries as separate corporations to prevent income shifting to tax havens. The document warns practitioners about the complexities of Disregarded Entities (DREs) and lists relevant legal citations in the footnotes.

People (1)

Name Role Context
Barack Obama President (Administration referenced)
Referenced in the header 'Obama Proposal' and 'Obama Administration' regarding tax policy.

Organizations (2)

Name Type Context
Obama Administration
Proposed the 2010 budget changes regarding foreign subsidiaries.
House Oversight Committee
Inferred from the Bates stamp 'HOUSE_OVERSIGHT'.

Timeline (2 events)

2011
Proposed effective date for the new tax regulations if adopted
USA
Circa 2009/2010
Release of Obama Administration 2010 budget proposals
Washington D.C.

Locations (2)

Location Context
Jurisdiction for federal tax purposes and individuals/businesses mentioned.
Mentioned as the target of the proposal to prohibit income shifting.

Key Quotes (3)

"The proposal is designed to prohibit the shifting of income from one foreign subsidiary to another in a tax-haven country."
Source
HOUSE_OVERSIGHT_026592.jpg
Quote #1
"Given the Obama Administration's heightened scrutiny of offshore tax havens and international tax abuses, this proposal is one to monitor closely."
Source
HOUSE_OVERSIGHT_026592.jpg
Quote #2
"The erosion of the check-the-box regulations and other DRE provisions continues to be a trap for the unwary."
Source
HOUSE_OVERSIGHT_026592.jpg
Quote #3

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