Media Mentions
2011
“Treasury, IRS Officials Preview Coming International Guidance”
Tax Notes Today, December 19, 2011
David Noren speaking at the annual IRS-GWU international tax conference, said that one of the most interesting aspects of recent IRS guidance on the subpart F foreign base company sales income rules was the statement in the preamble that the IRS and Treasury continue to study additional foreign base company sales income issues and may issue future guidance on when a branch should be treated as a separate corporation under the branch rule and the scope of, and relationship between, the foreign base company sales and foreign base company services rules.
David G. Noren, International Tax, Tax
“Ways and Means May Look at Subpart F in Territorial System, Committee Aide Says”
BNA Daily Tax Report, December 9, 2011
David Noren was noted as co-leader on a panel hosted by the D.C. Bar Section of Taxation’s International Tax Committee, which discussed specific changes that might be required under a proposal before the House Ways & Means Committee to move the U.S. toward a territorial tax system.
David G. Noren, International Tax, Tax
“U.S. Chamber Raises Concerns on Republican Overseas Tax Plan”
Bloomberg News, November 22, 2011
David Noren testified at a congressional hearing about a proposal to move toward a territorial tax system used by most other countries, in which overseas corporate earnings are exempt from domestic taxation. He said that there is a danger that the proposal tries too much to protect the domestic tax base. “The one thing that could push us outside of international norms would be if we got too aggressive in pushing base erosion and interfering with common business models,” Mr. Noren said.
David G. Noren, International Tax, Tax
“Tax Attorneys Praise Camp Territorial Plan at Hearing but Seek Changes to Subpart F”
BNA Daily Tax Report, November 18, 2011
David Noren observed that the success of congressional efforts to move the U.S. toward a territorial tax system with domestic tax exemption for offshore corporate earnings “will depend critically on the resolution of key design issues raised by exempting foreign subsidiary dividends.” Depending on how this and other issues are addressed, he added, a territorial tax system “could increase, decrease or have a roughly neutral effect on the overall U.S. tax burden on U.S.-based multinationals.”
David G. Noren, International Tax, Tax
“Territorial Draft’s Deemed Repatriation is Best Available Choice, Experts Testify”
Tax Notes Today, November 18, 2011
David Noren supported a provision for eight-year repatriation of U.S. corporations’ offshore profits as part of a bill to institute a territorial system of international taxation, saying it gives companies time to deal with possible liquidity issues when repatriating money invested overseas.
David G. Noren, International Tax, Tax
2010
David Noren spoke to Tax Analysts on August 19 about a newly passed federal bill for state fiscal relief that also makes substantial changes in the Foreign Tax Credit and other international tax provisions. The changes supersede earlier rule proposals, and Mr. Noren noted that "whereas it would have been difficult for an unwary taxpayer to stumble into the proposed regulations, the new statutory provision could apply to a range of everyday transactions in the absence of clarifying guidance" from the Treasury Department. He added that, because of the new law, Congress may have to consider other unpopular moves to increase revenue in a tax extenders bill expected this fall. "There really are no uncontroversial international revenue raisers," Mr. Noren stated. "In terms of getting the extenders bill through, Congress would lose the business community’s support if the bill has significant revenue raisers for transfer pricing and subpart F."
2006
David Noren was quoted in the November 1 issue of Euromoney Institutional Investor in an article concerning the need for corporate tax reform and the snails' pace at which it had progressed. "There doesn't seem to be a huge push to get anything done quickly…It's hard to be too optimistic about tax reform. I don't think anyone thinks the whole process is dead but it certainly hasn't got anywhere in the past year," Mr. Noren said.
David Noren was mentioned in the May 1 issue of the Legal Times and the April 1 issue of International Tax Review regarding his move from the Joint Committee on Taxation to McDermott.
David G. Noren, International Tax, Tax
David Noren was mentioned in the April 3 issue of the Washington Post regarding his move from the Joint Committee on Taxation to McDermott.
David Noren is listed in the March 31 issue ofThe Daily Deal regarding his move from the Joint Committee on Taxation to McDermott.
