OMB Receives Proposed Foreign Tax Credit Regs for Review
Posted on Nov 7, 2018 in International Tax
The Office of Management and Budget (OMB) received proposed foreign tax regulations for review on November 7. The regulations include guidance on allocation of expenses to the section 951A Global Intangible Low-Taxed Income (GILTI) basket for purposes of determining the foreign tax credit limitation, as well as transition rules for excess foreign tax credit carryforwards. The...
OIRA Receives Proposed Section 163(j) Regulations for Review
Posted on Oct 26, 2018 in Individual Taxation, International Tax, News, Pass-through Taxation, Tax Accounting
The Office of Information and Regulatory Affairs (OIRA) received draft proposed regulations under section 163(j), addressing the limitation on business interest deductions, on October 25, according to the Office of Management and Budget’s website. As amended by the Tax Cuts and Jobs Act (TCJA), section 163(j) generally limits business interest expense deductions to the sum of business...
Proposed GILTI Regulations to Be Published in Federal Register
Posted on Oct 8, 2018 in International Tax
The proposed regulations for the global intangible low-taxed income (“GILTI”) under section 951A (REG-104390-18) are set to be published in the Federal Register on October 10. Released on September 13, the regulations set forth new reporting requirements and rules for calculating GILTI inclusions. Public comments on the proposed GILTI regulations must be received by December 9. 2018,...
Proposed GILTI Regulations Released
Posted on Sep 13, 2018 in International Tax, News
The IRS has released proposed regulations on global intangible low-tax income (GILTI) under section 951A, a provision added by the Tax Cuts and Jobs Act. The proposed regulations set forth rules for calculating the GILTI inclusion and new reporting requirements, but do not address foreign tax credit rules, which will be addressed separately in the future. Public comments on the...
GILTI Regulations Reviewed by OMB
Posted on Sep 10, 2018 in International Tax, News
The Office of Management and Budget (OMB) has completed its review of global intangible low-tax income (“GILTI”) proposed regulations. Section 951A, enacted by the Tax Cuts and Jobs Act, generally taxes income earned by controlled foreign corporations at a reduced rate. Read more: OMB Completes Review of Regs on GILTI
Proposed GILTI Tax Regulations are Currently Under Review by the OMB
Posted on Aug 23, 2018 in International Tax, News
According to the Office of Budget and Management (OMB) website, the proposed regulations on section 951A were received on August 22, 2018 and are currently under review. Section 951A, a provision added by the Tax Cuts and Jobs Act, addresses the inclusion of global intangible low-taxed income by United States shareholders. Notice on OMB Website: Pending EO 12866 Regulatory...
AICPA and CIMA US Tax Reform Conference 2018
Posted on Aug 7, 2018 in International Tax
Eversheds Sutherland is the proud lead sponsor of the Association of International Certified Professional Accountants (AICPA) and the Chartered Institute of Management Accountants (CIMA) US Tax Reform Conference 2018 on September 17, 2018, at the Jumeirah Carlton Tower Hotel in London, United Kingdom. The US and International Eversheds Sutherland Tax team will be chairing the event and...
Tax Law Discourages U.S. Investment and Leaves Taxpayers in the Dark, According to New Report from Senate Finance Democrats
Posted on Jul 19, 2018 in News
A recent report released by the Senate Finance Committee ranking member Ron Wyden asserts that the new tax legislation has resulted in “more complexity, loopholes and incentives to ship jobs overseas.” According to the report, the global intangible low taxed income (“GILTI”) provisions create a new web of complexity and leave taxpayers in the dark regarding future investment decisions....
David Kautter Announces that Guidance on the Section 199A Pass-through Deduction will be Released in Weeks
On July 17, 2018, David Kautter, the acting Commissioner of the Internal Revenue Service (“IRS”), announced that the Treasury Department is currently reviewing guidance under section 199A and anticipates the guidance to be released within weeks. Kautter further stated that the IRS is treating the section 199A deduction, the section 59A base erosion and anti-abuse tax (“BEAT”), and the...Tax Reform 2.0 Not Expected to Address International Provisions
According to Republican Congressman Carlos Curbelo, tax reform 2.0 will not address international tax provisions, such as BEAT or GILTI. Instead, the next round of tax legislation is projected to focus on making the individual provisions permanent. The excluded provisions are expected to be addressed in a future, separate technical corrections bill. Curbelo also noted that the draft...Six Main Areas Identified For TCJA International Guidance
Posted on Jul 5, 2018 in International Tax, News
In anticipation of tax reform 2.0, six major international areas have been identified as prime for regulatory focus and guidance: the allocation of expenses to GILTI income; the application of the accumulated earnings tax under section 531 to GILTI; treatment of consolidated tax return filers for GILTI purposes; potential carve-outs to the base erosion and anti-abuse tax (or BEAT);...
Proposed Regulations Related to Previously Taxed Income (PTI) Are Expected This Year
Posted on Jun 26, 2018 in International Tax, News
Marjorie Rollinson, IRS Associate Chief Counsel International, has indicated that issuing new proposed PTI regulations is a priority for the IRS this year. The new PTI regulations would address issues related to the global intangible low-taxed income (GILTI) and deemed repatriation provisions of the Tax Cuts and Jobs Act, specifically, how to allocate deductions against tested income...
IRS Provides Timeline for Tax Reform Guidance
Posted on May 15, 2018 in International Tax, News
During the ABA Section of Taxation meeting in Washington, D.C. on May 12, David Kautter, the acting IRS commissioner, provided a rough timeline as to when IRS intends to release guidance related to the 2017 tax act. Kautter stated that a notice regarding section 965 (the so-called transition tax) may be released in the next two weeks and that proposed regulations are slated for release...
Eversheds Sutherland Releases Videocast Providing a Basic Overview of International Tax Provisions
Posted on Feb 7, 2018 in International Tax, News
Eversheds Sutherland (US) LLP recently released a videocast which provides a brief overview of the impact of international tax provisions. This short video provides a concise overview of various international provisions in the recent legislation formerly known as the Tax Cuts and Jobs Act, including those related to the reduced corporate tax rate, the shift to a hybrid...
Regulations and Notices to Provide Guidance on New Tax Bill
Posted on Feb 5, 2018 in International Tax, News
As the early guidance period for the new tax bill continues, the Treasury and IRS plan to shift to focusing on developing regulations over the next six months. A less notice-oriented approach is expected, with only five to ten limited-scope notices addressing basic questions, such as section 163(j) business interest issues, anticipated. IRS and Treasury tax reform projects will be...