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