On August 1 2014, U.S. Representative Sander Levin released a discussion draft of the Stop Corporate Earnings Stripping Act of 2014. One of the main changes introduced by the draft bill are to section 163(j) of the Internal Revenue Code, which concerns earnings stripping. The changes include:
- Reducing a U.S. company’s permitted net interest expense to no more than 25% of the company’s adjusted taxable income
- Removing the 1.5:1 debt-to-equity safe harbor
- Limiting the carry forward period for …