September 2022 / United States

The US Treasury Department (Treasury) has reissued its list of countries that require cooperation with, or participation in, an international boycott as a condition of doing business.

The Treasury published the list in the Federal Register on 3 October 2022.

The list, which is unchanged from the previous list published on 5 July 2022, includes the following eight countries:

• Iraq;
• Kuwait;
• Lebanon;
• Libya;
• Qatar;
• Saudi Arabia;
• Syria; and
• Yemen.

The listed countries are identified pursuant to section 999 of the US Internal Revenue Code (IRC), which requires US taxpayers to file reports with the Treasury concerning operations in the boycotting countries. Such taxpayers incur adverse consequences under the IRC, including denial of US foreign tax credits (FTCs) for taxes paid to those countries and income inclusion under subpart F of the IRC in the case of US shareholders of controlled foreign corporations (CFCs) that conduct operations in those countries.

US President Joe Biden has committed to push for further corporate tax reform and individual income tax relief in his administration's Economic Blueprint released on 9 September 2022. The US White House announced the release of the Economic Blue Print in a 9 September 2022 press release.

The Economic Blueprint includes a worker-centric tax reform as one of its pillars (see Note). Specifically, the President will push to reward work, rather than wealth, by:

• permanently extending the expanded Child Tax Credit (CTC) and Earned Income Tax Credit (EITC);
• making further structural reforms to the US Internal Revenue Code (IRS) to:
  • remove incentives to offshore jobs and profits;
  • meet the United States' obligations under the international global tax agreement;
  • close tax loopholes for the rich (including the Medicare tax loophole); and
  • return to pre-Tax Cuts and Jobs Act (TCJA) rates for taxpayers with income of more than USD 400,000;
  • closing the carried interest loophole;
  • ending the step-up in basis for taxpayers at the top; and
  • imposing a Billionaire Minimum Tax.

Note: The President's Economic Blueprint also includes the following as pillars:

• empowering US workers;
• making and building it in the United States;
• giving US families breathing room; and
• making the US industry more competitive, less concentrated and more resilient.