US: IRS issues guidance for computing the “transition tax” on foreign earnings
On 29 December 2017, the Treasury Department and the Internal Revenue Service issued Notice 2018-07, which provides guidance for computing the “transition tax” under recent tax legislation enacted on Dec. 22, 2017. In general, newly-issued
See MoreUS: The Nation’s tax season will begin 29 January 2018
On January 4, 2018, the Internal Revenue Service announced that tax collection will begin on Monday, January 29, 2018, and taxpayers are reminded of certain tax credits that the refunds will not be available until the end of February. The IRS will
See MorePGA Highlights: December 2017
In the United States the following events have taken place under the several PGA during the month of December 2017. Agencies Summary Federal Register Notice of request for panel review: A request for panel review was filed on behalf of the
See MoreUnited States: ADD/CVD Roundup for December 2017
Following table shows the Federal Register notices related to ADD/CVD cases for December 2017 in United States. Country Product Investigations Case Number Details Argentina Biodiesel Postponement of Final Determinations of Sales in Less Than
See MoreUS Tax Cuts and Jobs Act: Global Intangible Low-Taxed Income
The US Tax Cuts and Jobs Act has introduced various new provisions to counter base erosion and profit shifting by US corporations. These include a base erosion minimum tax, provisions to counter income shifting by intangible property transfers and
See MoreUS Tax Cuts and Jobs Act: Income Shifting by Intangible Property Transfers
A U.S. person transferring intangible property to a foreign corporation in a transaction that would otherwise qualify for non-recognition treatment is generally treated as having sold the intangible property in exchange for payments contingent on
See MoreUS Tax Cuts and Jobs Act: Hybrid Transactions and Hybrid Entities
A group could set up an entity that is treated as fiscally transparent for U.S. federal tax purposes but is treated as an entity in the country in which it is resident or subject to tax. Similarly, an instrument may be treated as debt in one country
See MoreUS Tax Cuts and Jobs Act: Base Erosion Minimum Tax
The Tax Cuts and Jobs Act provides for a participation exemption in the form of a 100% deduction for the foreign-source portion of dividends received from 10%-owned foreign corporations. This deduction for dividends received can eliminate additional
See MoreUS: President signs tax cuts and jobs act
On December 22, 2017, President Donald Trump signed the Tax Cuts and Jobs Act (TCJA). On 20 December 2017, both the US Senate and the House of Representatives approved the passing of the Tax Cuts and Jobs Act with some minor changes to comply
See MoreUS: Senate passes long awaited tax reform bill
On December 3, 2017, the Senate has accepted nearly $ 1.5 trillion of Republican tax bills, a historic volume and urgent political priority for President Donald Trump and his party. The poll was 51-49, mostly along party lines. Not a single
See MorePGA Highlights: November 2017
In the United States the following events have taken place under the several PGA during the month of November 2017. Agencies Summary Federal Register General notice of ACE becoming the sole EDI system: From December 9, 2017, Automated
See MoreUnited States: ADD/CVD Roundup for November 2017
Following table shows the Federal Register notices related to ADD/CVD cases for November 2017 in United States. Country Product Investigations Case Number Details Belarus Certain Carbon and Alloy Steel Wire Rod Affirmative Final Determinations
See MoreUS: Senate finance committee proposes to tax cut for US beverage industry
The Senate Finance Committee included provisions to reduce the tax burden on US brewers and distilleries for two years, and to allow wine producers a permanent tax cut. The proposal lowers the tax on beer to $ 16 a barrel on the first six million
See MoreU.S. and Italy sign an agreement on the exchange of CbC reports
According to an IRS announcement on its website, the competent authorities of the U.S. and Italy have concluded an arrangement on the exchange of Country-by-Country Reports. The competent authority arrangement (CAA) for exchange of
See MoreUS: IRS issues a correction on tax regulations
The US Tax Administration (IRS) issued a correction to tax ordinances (TD 9803) on November 15 regarding the transfer of ownership of foreign corporations. These rules, which were published on 16 December 2016, retrospectively removed the exemption
See MoreUS: Senate Finance Committee approves tax reform bill
On November 16, 2017, the US Senate Finance Committee completed its tax reform and approved the bill. The bill, approved by the Finance Committee ("the SFC Bill"), contains a number of changes to the original proposed reform ("Chairman's Mark") as
See MoreUS: IRS releases practice units on APAs for tangible goods transactions
On November 6, 2017, the Internal Revenue Service (IRS) released two new international Practice Units (IPUs) in connection with Advance Pricing Agreements (APAs) for inbound and outbound tangible goods transactions. The IPUs provide a summary of the
See MoreUS: Tax reform bill published
The long awaited US tax reform bill was released by House Republicans on 3 November 2017. The impact on the deficit is estimated at $1.5tn over 10 years. The corporate tax rate would be reduced from the current 35% down to just 20% starting in 2018.
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