Tax Cuts and Job Act News

This webpage presents a collection of recent articles which address the impact of the Tax Cuts and Jobs Act on U.S. multinational businesses.

  • Tax Cuts Chaos, Part III: Can Treasury Fix It?

    Tax Analysts 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.

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    By Herzfeld, Mindy, posted on Friday May 18, 2018
  • 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.

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    By Ring, Diane, posted on Sunday May 13, 2018
  • Global dividends grow on back of US corporate strength

    Financial Times 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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    By Murphy, Hannah, posted on Sunday May 20, 2018
  • Big tech ploughs money into capex and buybacks

    Financial Times By: Miles Johnson (Financial Times)

    Large US technology companies are investing far more in their businesses as a percentage of revenues than many non-tech peers in spite of spending billions of dollars on share buybacks at the same time. US companies are expected by analysts at JPMorgan to buy back about $800bn of their stock this year, with corporate coffers boosted by corporate tax reform.

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    By Johnson, Miles, posted on Wednesday May 16, 2018
  • Small Caps Set New Highs, Outpacing Their Multinational Peers

    WSJ logo By: Akane Otani and Michael Wursthorn (The Wall Street Journal)

    Shares of small U.S. companies climbed to a fresh record Wednesday, reflecting their gains in the recent tax overhaul and signs that U.S. growth once again looks more robust than that from overseas.

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    By Otani, Akane; and Wursthorn, Michael, posted on Wednesday May 16, 2018
  • Reassessing the Beloved Double Irish Structure in Light of GILTI

    Tax Analysts By: Lewis J. Greenwald, Witold Jurewicz & John Wei

    In this article, the authors discuss the new global intangible low-taxed income provisions of the Tax Cuts and Jobs Act and reassess the double Irish structure and whether it continues to deliver tax savings.

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    By Greenwald, Lewis J.; Jurewicz,Witold; Wei, John , posted on Wednesday May 9, 2018
  • TCJA Is Missed Opportunity, Experts Say

    Tax Analysts By: Amanda Athanasiou

    The Tax Cuts and Jobs Act won’t meaningfully reduce base erosion or profit shifting, but it does encourage the offshoring of economic activity and real assets, according to some experts.

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    By Athanasiou, Amanda, posted on Tuesday May 8, 2018
  • IRS Wary of TCJA-Motivated Changes to Transfer Pricing Practices

    Tax Analysts By: Ryan Finley

    Taxpayers that reverse their established transfer pricing positions in ways that favorably affect their liability under the Tax Cuts and Jobs Act’s base erosion and antiabuse tax will likely face heightened IRS suspicion.

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    By Finley, Ryan, posted on Monday May 14, 2018
  • GILTI State Tax Issues

    Tax Analysts By: Lee Sheppard 

    States normally excuse corporate income taxes on foreign income. Mechanically, these exclusions usually involve a special state-level dividends received deduction for foreign dividends and deemed dividends. So states that start with federal taxable income will first include GILTI in the state tax base, then apply their DRD for foreign dividends to GILTI. State DRDs generally do apply to federal deemed dividends. But a state DRD may not cover 100 percent of the dividend; often there is a sliding scale based on proportionate ownership.

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    By Sheppard, Lee, posted on Monday May 14, 2018
  • Consolidated Group Questions More Pressing for 'GILTI' Than 'BEAT'

    Bloomberg By: Allyson Versprille (Bloomberg BNA)

    Practitioners are eagerly awaiting guidance from Treasury specifying how new international tax provisions will apply in the context of consolidated groups, but some provisions are piquing more interest than others.

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    By Versprille, Allyson, posted on Monday May 14, 2018