Why the Emphasis on Tax Reform?
Tax reform is an area that even an armchair American political strategist can identify as a subject that will resonate with the American public. It was Justice Sutherland in the quintessential 1935 Supreme Court decision Gregory v. Helvering who acknowledged that structuring one’s business affairs in a manner that results in paying the least possible tax is a part of the American way of life. With recent budget shortfalls in the United States, attributable to the “Great Recession” we are living through, coupled with massive new governmental spending programs, there is even greater need to replenish federal and state revenue streams.1 The system of international taxation has long been the target of criticism due to its complex rules that may encourage “tax planning” strategies by multinational corporations intended to eliminate or evade U.S. taxation. Thus, the timing of the Obama administration’s current push to reform international tax may simply be a fortuitous opportunity to change
