Last week, Senate Finance Committee Chairman Ron Wyden (D-OR) released proposals that would implement a new stock buyback excise tax and significantly reform the partnership tax rules. These two proposals are the latest in a series of revenue raising proposals that the Chairman has put forth for consideration as potential funding mechanisms for the pending reconciliation bill. In recent months, Senator Wyden has released significant proposals addressing carried interest, derivatives, and international tax. Further, it is anticipated that he may release an additional proposal providing statutory text with respect to the "mark to market" white paper he released in 2019. Many of Chairman Wyden's proposals, as well as additional revenue raising proposals, were included in a "menu" document that reportedly was presented to the Democratic members of the Senate Finance Committee for consideration.

The Wyden proposals would significantly change major portions of the tax code and, in the process, raise significant amounts of revenue. As the House Committee on Ways and Means continues its markup of the reconciliation bill this week, it will be interesting to see if any of them will be incorporated. And, of course, when the bill moves to the Senate, these proposals will certainly be on the table for consideration. Even if some of Chairman Wyden's proposals do not make it into the reconciliation bill, it will be important to see if any of them resurface in future legislative vehicles, including a potential end-of-year package. In any event, now that these proposals have seen the light of day, impacted taxpayers are encouraged to review them and engage with Senate Finance Committee staff with any concerns. #TaxTake

Upcoming Speaking Engagements and Events

Loren will speak at the 2021 WITA Virtual Intensive Trade Seminar on a panel titled, "International Tax and Trade," on September 13.

On September 21, Marc will speak at the 2021 ICI Tax Accounting Conference on a panel titled, "Biden Administration's Legislative and Regulatory Agenda."

On September 23, Loren and fellow Member Kevin Kenworthy will provide a Litigation Update at API's 86th Annual Federal Tax Forum.

Marc will speak at the 56th Annual Southern Federal Virtual Tax Institute on a panel titled, "The 2021 Legislative Landscape: Evaluating Actual and Potential Changes," on October 25.

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