MINOR MEMOS. A bill that is gaining ground in the US Senate would create a blacklist of 40 countries considered tax havens. Corporations in such countries that are subsidiaries of US parent companies would be taxed on worldwide income as if they were American companies. The bill is S. 396. It is being promoted by Senators Byron Dorgan (D-North Dakota) and Carl Levin (D-Michigan). The blacklisted countries include the Cayman Islands, Bermuda, the British Virgin Islands and Mauritius. One commentator said the day before any such new law takes effect, there will be no subsidiaries of US corporations in any of the blacklisted countries . . . . Another bill that is picking up support in the House would shut down a lucrative business being done by some US banks in hybrid loans to foreign corporations. The loans are structured to qualify as an equity investment for US tax purposes, but as debt in the foreign country where the borrower is located. Payments received by the US lender are reported as dividends that qualify for a reduced tax rate of 15% through 2010. However, because the payments are reported as interest by the borrower in its home country, they can be deducted by the borrower. The bill, introduced by Rep. Richard Neal (D-Massachusetts), would deny the 15% tax rate for dividends that the payor treats as deductible in its home country or on instruments that are not treated as stock in the foreign country. It is H.R. 1672. Neal is a senior member of the House tax-writing committee.