• Carried Interest Provisions and Foreign Account Tax Compliance Act Proposed as Offsets for Extenders Bill
  • December 21, 2009 | Authors: Brian Kniesly; David I. Shapiro
  • Law Firm: Fried, Frank, Harris, Shriver & Jacobson LLP - New York Office
  • Yesterday, Representative Rangel of New York introduced the “Tax Extenders Act of 2009” (the “Bill”) in the House. The Bill would extend through the end of 2010 more than forty tax relief provisions that are scheduled to expire at the end of 2009. Of greater note, these provisions would be paid for by (i) imposing compliance provisions substantially similar to those in the “Foreign Account Tax Compliance Act of 2009” directed at curbing offshore tax evasion, (ii) subjecting certain “dividend equivalent payments” to US withholding taxes, and (iii) taxing carried interest as ordinary income under provisions substantially similar to those included in Representative Levin’s carried interest bill introduced earlier this year.