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    House Approval of Budget Resolution Sets Stage for ACA Repeal

    The House on January 13 approved a fiscal 2017 budget resolution setting January 27 as the nonbinding deadline for congressional tax and health committees to draft budget reconciliation legislation repealing the Affordable Care Act.
    House passage of S. Con. Res. 3, by a 227-198 vote, came one day after Senate lawmakers approved it during a middle-of-the-night marathon voting session. The House action wraps up a week of partisan debate in which President-elect Donald Trump and GOP leaders tried to quash criticism from Democrats that Americans would lose coverage if the ACA is repealed without an immediate replacement.

    Head of Dutch Tax Agency Resigns Suddenly

    The head of the Dutch Tax and Customs Administration, Hans Leijtens, on January 13 submitted his resignation because he no longer considers himself the right person to carry out his duties, according to a brief press release posted on the central government's website.
    Leijtens was in his post only for a little over 14 months. According to the Dutch press, his tenure was marked by a period of turmoil.

    Final, Temporary Regs Address Post-Inversion Tax Avoidance Deals

    The IRS has issued final and temporary regulations (T.D. 9812) providing guidance on determining stock ownership and rules regarding inversions and related transactions. The final regs adopt, with changes, proposed regs (REG-135734-14) issued in 2016. The corresponding temporary regs (T.D. 9761) are removed.
    The final regs identify specified stock of a foreign corporation that is disregarded in calculating ownership of the foreign corporation for determining whether it is a surrogate foreign corporation. 

    Legislative Outlook: Mnuchin to Be Considered for Treasury

    The Senate Finance Committee will hold a hearing January 19 to consider former Goldman Sachs banker Steven Mnuchin as President-elect Donald Trump's pick to head the Treasury Department.


    Mnuchin has said that the Trump administration views tax reform as its "number one priority," with "the largest tax change since Reagan" designed to increase U.S. economic growth 3 to 4 percent per year on a sustained basis. He has also floated the idea that unspecified deductions will be "absolutely limited to pay for this," including capping the mortgage interest deduction for homeowners.

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    IRS Changes Coveted QI Agreement Terms, Imposes Greater Burdens

    Qualified intermediaries subject to withholding and reporting requirements, including those seeking to become qualified derivatives dealers, should be wary of some unexpected changes in the IRS's final QI agreement and additional operational burdens, according to practitioners.
    The IRS incorporated changes in the final QI agreement (Rev. Proc. 2017-15, 2017-3 IRB 1)by reference to the new temporary chapter 3 regs (T.D. 9808), concerning due diligence rules and treaty claims for limitations on benefits, Laurie Hatten-Boyd of KPMG LLP told Tax Analysts.

    U.K. Defends Work Helping Developing Nations Adapt to New Tax Standards

    The U.K. Department for International Development (DFID) has defended itself against a recent report from an aid watchdog criticizing it for failing to do enough to help developing nations benefit from new tax standards, noting its progress in boosting developing countries' tax administration capacity.

    In a report published on September 27, the Independent Commission for Aid Impact (ICAI), which scrutinizes U.K. aid spending, noted that the DFID has made some good progress in building capacity in its partner developing countries to adapt to international tax standards led by the G-20 and OECD.

    Officials Open to Clarifying Political Subdivision Regs

    Officials on June 6 appeared willing to clarify provisions in controversial proposed regulations that would redefine the meaning of political subdivision in issuing tax-exempt bonds.
    At a hearing at IRS headquarters in Washington, Spence Hanemann, branch 5 attorney, IRS Office of Associate Chief Counsel (Financial Institutions and Products), acknowledged concerns expressed in more than 100 comments on REG-129067-15 (Doc 2016-3660), which came out in February and has been criticized by representatives of the public finance community who fear it will cause uncertainty and disruption in the financial markets. The proposed regs say that to qualify as a political subdivision, an entity must be governmentally controlled, with control defined as ongoing rights or power to direct significant actions of the entity. (Prior coverage (Doc 2016-3702).)
    A political subdivision must also serve a governmental purpose and provide a significant public benefit, with no more than incidental benefit to private persons. The proposed regs retain the requirement that a political subdivision be able to exercise at least one sovereign power -- eminent domain, police power, or taxing power.

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