Uncertainty Over Tax Reform Not Halting Drive for IRS Pacts - Bloomberg BNA
John Warner, Shareholder in the firm's Tax section, is quoted in Bloomberg BNA's article "Uncertainty Over Tax Reform Not Halting Drive for IRS Pacts."
“I kind of take that out of the prognostication, which is not to say that some companies would not have that in the back of their mind,” said John Warner, a member of Buchanan Ingersoll & Rooney PC in Washington. “Given the lack of political success the administration has had, not to mention the lack of any detailed plan they’ve set out, you’ve got to wonder what the odds are that you can come close to predicting what the U.S. corporate environment is going to look like, even if there is tax reform.” ...
The lengthy APA process, often a matter of years, is another complication in the calculus facing taxpayers. Corporations and advisers must weigh the possibility that the playing field will change while the agreement is being negotiated, prompting a decision on whether to pull out of the application.
“It’s an expensive process, and a lot of taxpayers are going to say, ‘I’m not going to spend my resources if I think there’s only a 60 percent chance I’m going to go through with it,’” Warner said.