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TOP TREASURY TAX POLICY POST FINALLY FILLED

May 27, 2005

The long-vacant top tax policy post at the Treasury finally has an appointee. President Bush announced that he will nominate Phillip D. Morrison as Assistant Secretary for Tax Policy. The post has either been vacant or filled on an "acting" basis since early last year.

With the President's Advisory Commission on Tax Reform set to release its report in the coming weeks, Mr. Morrison will have his hands full. He leaves a post with Delloite and Touche. He was the Treasury's International Tax Counsel from 1989 to 1992.

Mr. Morrison has an article on the prospects for reforming the taxation of international activity available here. An excerpt:

n certain respects, it is still true that the United States has the harshest, and therefore the most anti-competitive, anti-deferral regime of all the OECD countries. Check-the-box has also made Subpart F taxation elective with respect to dividend, interest, rent and royalty payments among CFCs, except in those jurisdictions where per se corporations must be used, thereby creating an unfair situation for those latter companies. With improved transfer pricing clarity and enforcement in the last 15 years, the foreign base company sales and services rules have only capital export neutrality as support and CEN has been somewhat discredited in recent years. Likewise, the lack of sensible loss allowance rules in Subpart F and the lack of a meaningful de minimis rule create a certain level of unfairness and complexity that should be carefully considered. Given these continuing issues, it would be surprising if Subpart F reform were not the subject of at least some renewed debate during 2005-2006 if there is any corporate tax reform debate at all, though many tax directors may be inclined to let sleeping dogs lie.

Link: Tax Analysts Coverage (free)

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