Tax Cuts and Jobs Act News
Tax Cuts Chaos, Part III: Can Treasury Fix It?
By: Mindy Herzfeld
The code changes made by the Tax Cuts and Jobs Act (P.L. 115-97) have wreaked havoc on international rules, creating taxpayer uncertainty in how to apply the law and headaches for the government in how to write interpretive rules. Much of the complexity comes from a single source: the delineation of global intangible low-taxed income as a separate basket under section 904(d). That construct brings expense allocation rules into play, potentially restricting U.S. multinationals’ ability to claim foreign tax credits on GILTI in unexpected ways.
The Stages of International Tax Reform
By: Diane Ring
Since December 2017, tax conferences in the United States have focused substantially on the H.R. 1 tax reform legislation. No surprise there — the 2017 changes are among the most significant in the past thirty years. But over the past five months, through attending numerous tax conferences featuring international tax practitioners, I’ve observed some interesting developments in the nature of the discussions and debates at these conferences. These changes are pretty revealing about the process of absorbing the true impact of the new tax law, particularly in international tax. This weekend’s ABA May Tax Section Meeting in Washington, D.C. highlighted some of these trends.
Global dividends grow on back of US corporate strength
By: Hannah Murphy (Financial Times)
Global dividends grew by more than 10 percent in the first quarter of 2018, boosted by favourable exchange rates and as US companies started to pay out windfalls from President Donald Trump’s tax reforms.
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Sweden Plans New Tax Liability for Foreign Companies
By: Marcus Hoy (Bloomberg BNA)
Foreign employees of non-resident companies will be tax-liable regardless of the length of time they stay in the country, according to a draft proposal detailed by Sweden's Finance Ministry May 17. If, as expected, the proposal become law, foreign companies employing workers in Sweden will be required to deduct tax from salaries even if the company doesn't have a permanent establishment in the country.
U.N. Releases Updated Model Tax Convention
By: Alexander Lewis
The U.N. published on May 18 its updated model tax treaty, which features new provisions covering fees for technical services and entitlement to treaty benefits.
S. 2826 Would Establish Tax on Income From China
By: Tax Analysts
Excerpts are available of S. 2826, the Fair Trade with China Enforcement Act, introduced by Sen. Marco Rubio, R-Fla., which would eliminate the reduced withholding rates for Chinese residents and impose a surtax on specific income from China, among other things.
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