Neil is the CEO of Sevara Capital Advisors. He is passionate about solving tax, accounting and regulatory problems for institutions that have invested billions of dollars of capital in multiple jurisdictions. His company provides solutions for banks, insurance companies and hedge funds to tackle their problems related to tax returns, financial statements, accounting and internal finance matters. Neil holds a master’s degree in Law from the University of Cambridge.
In 2015, in the wake of the financial crisis, the Treasury Inspector General for Tax Administration published a report, detailing the policy issues involved in the administration of Net Operating Losses (NOLs). It is time to act on this report and to give corporations a straightforward way to trade their losses on an exchange, or at least in a Treasury-approved dark pool.
The Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (BEPS) marks the culmination of a project that began some five years ago to save between $100bn-$240bn of taxes currently estimated to be avoided by multi-national corporations such as Apple, Amazon and Alphabet.
If the Senate passing a budget has moved the needle towards passing tax reform and, assuming the closed-door drafting of coherent tax legislation produces something that lawmakers can read and understand, the Internal Revenue Service (IRS) will have to start administering new rules very quickly indeed if any aspects of the new law are retroactive to 2016. It is worth looking at the IRS and its role to see if it is likely to be up to the task.
The US Tax Reform is still being formed in the abattoir of Washington DC. Since the reform proposal has a lot to say about the relative roles and tax rates applied to corporations and partnerships, it is time to take a quick look at the history of these.
Having described the taxonomy of the US Tax Code in the last article, it is worth taking a look at two of the most discussed areas of the Code: Partnerships (Subchapter K) and Corporations (Subchapter C).
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