Tax Cuts and Jobs Act News
By: Laura Davison (Bloomberg BNA)
The Internal Revenue Service is closely examining how companies with complex structures can calculate a deduction for intangible income derived from serving foreign markets, an agency official said.
By: Chester Dawson and Theo Francis (The Wall Street Journal)
Ohio-based auto parts supplier Dana Inc. plans to relocate its corporate address to the U.K. for tax purposes if a takeover bid announced Friday is successful, a move that comes just weeks after passage of U.S. tax legislation designed to discourage American companies from doing just that.
By: Tax Analysts
Pam Olson of PwC has asked Treasury to address two anomalies that have occurred in measuring the cash position under section 965’s transition tax, the first of which involves cash contributed or lent by the U.S. parent to its foreign subsidiaries in completing an acquisition and the second is Treasury’s authority to promulgate regulations carrying out section 965’s purpose.
By: Andrew Velarde
Final U.S. anti-inversion regulations that would follow up on temporary and proposed regs are forthcoming, but what this means for a prominent case currently on appeal is uncertain. The news came to light in a request from the government in its March 9 motion for a stay of briefing in its appeal to the Fifth Circuit in the closely watched case, Chamber of Commerce v. IRS, No. 17-51063. The opening brief is due March 16, but the government is requesting a stay until the regs are published.
By: Bjarke Smith-Meyer
Critics warn the sheer volume of such agreements hampers the Commission’s ability to identify the worst tax-avoidance cases.
By: Joe Kirwin (Bloomberg BNA)
The European Parliament overwhelmingly approved terms for tax alignment between the EU and the U.K. once it leaves the bloc. Members of parliament have previously said the alignment is needed to prevent the U.K. from adopting corporate tax levels far below those in the EU, as many are expecting.