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U.S. Bill Introduced to Target Hopscotch Lending and Decontrolling

19 May 2016

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Proposed Changes

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United States

On 17 May 2016, U.S. House Ways and Means Committee ranking minority member Sander M. Levin D-MI introduced the Protecting the U.S. Corporate Tax Base Act of 2016. The bill calls for stricter anti-inversion rules against hopscotch lending and decontrolling - two common tax avoidance practices. A hopscotch loans allows a foreign parent or affiliate to bypass U.S. taxation by borrowing deferred earnings of a newly acquired U.S. controlled foreign corporation (CFC). The rules would go further than those issued by the Treasury Department in April, as they would apply to any multinational company acquired by a foreign company, not...