Focus Of The Hearing:
The hearing will focus on the Ways and Means discussion draft released on October 26, 2011. For purposes of this hearing, the Subcommittee is particularly interested in comments and analysis of the basic architecture of the draft exemption system, including the scope of the 95 percent exemption for certain dividends and capital gains, the treatment of different forms of entities and ownership structures, and the transition rule applied to pre-effective date earnings. The hearing also will review the various options for protecting the U.S. tax base, both with respect to thin capitalization rules and income-shifting through the location of intangible property and similar means.
Witness List:
Mr. John L. Harrington, Partner, SNR Denton, Washington, DC.
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Mr. Tim Tuerff, Partner, Deloitte Tax LLP, Washington, DC.
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Mr. David G. Noren, Partner, McDermott, Will & Emery, Washington, DC.
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Mr. Paul W. Oosterhuis, Partner, Skadden, Arps, Slate, Meagher & Flom LLP & Affiliates, Washington, DC. Testimony Truth in Testimony
Dr. Martin A. Sullivan, Contributing Editor, Tax Analysts, Alexandria, VA.
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