The Congressional House tax reform task force will release its comprehensive tax reform blueprint at the end of June, in time for the Republication National Convention in early July, according to Ways Means Committee Chairman Kevin Brady (R-TX). The Chairman was also quoted as saying there would be additional hearings in May to address various tax priorities of lawmakers.

On the Senate side, the Finance Committee on 26 April held a hearing on business tax reform, focusing mostly on last year's business tax working group report, but also underscoring the need for international tax reform. Finance Committee member Charles Schumer (D-NY) said during the hearing that he remains ready to work with Committee Chairman Orrin Hatch (R-UT) to move first on international tax reform, possibly even this year. Senator Schumer and Finance Committee member Rob Portman (R-OH) were the co-leaders of the Committee's international tax working group that released their report in the summer 2015.

In other news, a Treasury official was quoted as saying the Administration has not decided whether or not to expand the new rules limiting post-inversion planning beyond the inverter companies. The official specifically referenced hopscotch loans and decontrolling controlled foreign corporations as areas that could be expanded beyond the scope of inverters.

Robert Stack, Treasury deputy assistant secretary (international tax affairs) said this week that Treasury and the IRS are committed to resolving the gap year issue with respect to country-by-country (CbC) reporting for 2016, by allowing optional CbC reporting for 2016. Stack noted, however, that more work is needed to ensure that allowing optional CbC reporting will be effective in shielding US multinationals from local filing requirements. According to press reports, Stack noted that "[w]hat everybody has to appreciate is there's no victory [in] accepting voluntary filings if the other countries that are our partners in country-by-country [reporting] are not going to accept them as good filings and therefore obviate the need for local filing."

New IRS Associate Chief Counsel (international) Marjorie Rollinson recently offered up her top guidance priorities for the coming summer. She is committed to finalizing the Section 385 regulations, Section 367(d) regulations on the transfer of intangibles, and issuing final regulations under Section 721(c) that would address transfers of property to partnerships with foreign partners and that are described in IRS Notice 2015-54.

The IRS is also planning to release a notice that includes a new draft 2017 qualified intermediary (QI) agreement that will have two major changes. Another IRS official this week said the new QI agreement would address the qualified derivatives dealer regime in the new Section 871(m) regulations, as well as changes to certain existing compliance procedures in the current 2014 QI agreement.