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February 9, 2024

Report on recent US international tax developments 9 February 2024

Senate Republicans reportedly are reaching consensus that the House-passed $78 billion Tax Relief for American Families and Workers Act of 2024 (H.R. 7024) will require a Finance Committee markup, which would slow passage of the proposed legislation. The bill, passed by the House on 31 January, would address certain TCJA business measures, the Child Tax Credit, the US-Taiwan double tax relief and other issues. Among the most pressing measures in the bill for businesses is restoration of IRC Section 174 expensing for domestic R&D (but not foreign R&D) and the prior IRC Section 163(j) interest deductibility parameters, retroactive to 2022 (with elections) and extended through 2025.

The Senate is out for a two-week Presidents Day recess beginning next week through 23 February. Senate Democratic leaders have not expressed an inclination for a Finance markup, which would require the bill to go back to the House for another vote if changes are made.

The Senate will also have to focus on looming government funding deadlines — 1 March and 8 March — when it returns to Washington.

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Contact Information

For additional information concerning this Alert, please contact:

Ernst & Young LLP (United States), International Tax and Transaction Services, Washington, DC

Published by NTD’s Tax Technical Knowledge Services group; Carolyn Wright, legal editor