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U.S. Legislation Targeting Corporate Earnings Stripping Introduced

26 February 2016

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Proposed Changes

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United States

On 23 February 2016, U.S. Representatives Sander Levin (D-MI) and Chris Van Hollen (D-MD) introduced the Stop Corporate Earnings Stripping Act. The bill is similar to legislation introduced in 2014 and 2015, and is meant to prevent earnings stripping of corporations that are related to inverted corporations. It includes: Limiting the carry forward period for disallowed interest expense to 5 years; Disregarding the 1.5:1 debt-to-equity ratio; Limiting a U.S. corporations permitted net interest expense to no more than 25% of its adjusted taxable income; and Repealing the excess limitation carry forward. If approved, the measures would apply in relation to...