Tax policy is increasingly taking centre stage of the US political scene. The Democrats and Republicans agree that there is a need for wholesale overhaul of the US tax code but that's where the consensus ends. This report examines the latest debate on US tax policy and includes reflections on the way tax policy is made. It also covers recent technical developments for advisers including: why the US tax landscape encourages US groups to migrate; key employment tax issues; the UK/US double tax treaty and the problem of entity classification; transfer pricing issues for taxpayers operating between the UK and US; how financial institutions are coping with the FATCA regime; problems created by the new US withholding regime; recent IRS scrutiny of inbound financing; why US groups should re-evaluate their UK financing structures; the new requirements for bearer bonds of US issuers; an update on American depository receipts;...
