U.S. International Tax This Week for the Week Ending August 24

26 August 2018

Ernst & Young's U.S. International Tax This Week newsletter for the week ending August 24 is now available. Prepared by Ernst & Young's International Tax Services group, this weekly update summarizes important news, cases, and other developments in international taxation.

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Spotlight

The IRS proposed regulations on the inclusion of global intangible low-taxed income (GILTI) under Section 951A are under review by the Office of Management and Budget (OMB) Office of Information and Regulatory Affairs (OIRA), suggesting they are close to being released. Section 951A was enacted by the Tax Cuts and Jobs Act (TCJA) last December. According to OIRA, the regulations were received for review on 22 August. Although the general timeline for review is 45 days, under a regulatory review agreement between the two agencies announced earlier this year, the Treasury Department can request that OMB review of TCJA regulations be completed within 10 business days. This timeline may be extended by mutual agreement by Treasury and OMB.

This week, the IRS also issued a set of draft forms relating to the GILTI and foreign-derived intangible income (FDII) provisions. Note that the draft forms are subject to change. The IRS releases draft forms here. Final IRS forms are released here.

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Upcoming Webcasts

Managing the impact of increased global tax controversy risk - insights for business leaders (September 11)
Businesses are facing multi-country, multi-issue tax controversy risk in an increasingly interconnected global environment. During this Thought Center Webcast, Ernst & Young professionals will discuss how this global interconnectivity is shaping the tax controversy landscape and what leading companies are doing to better manage tax controversy risk across the organization.

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Recent Tax Alerts

Africa

— Aug 20: Mauritius enacts changes to tax regime for corporations with global business licenses (Tax Alert 2018-1658)

Asia

— Aug 20: Certain Chinese input VAT receivables may be refundable (Tax Alert 2018-1660)

— Aug 20: Malaysian Lower House passes Sales and Service Tax legislation (Tax Alert 2018-1659)

— Aug 16: China announces elimination of Hong Kong, Taiwan and Macau residents' work authorization application (Tax Alert 2018-1644)

Canada & Latin America

— Aug 20: Tax reform bill submitted to Colombia's Congress (Tax Alert 2018-1663)

— Aug 17: Colombia requires certain foreign service providers to register with Colombian tax registry for VAT purposes (Tax Alert 2018-1654)

Europe

— Aug 23: Portugal publishes Ministerial Order regulating Beneficial Owner Central Registry (Tax Alert 2018-1680)

— Aug 23: Luxembourg-Senegal double tax treaty enters into force (Tax Alert 2018-1677)

— Aug 20: Finland issues draft bill for public consultation regarding changes to CFC rules (Tax Alert 2018-1661)

Oceania

— Aug 17: Australia's new reporting requirements and denial of deductions discussed (Tax Alert 2018-1655)

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IRS Weekly Wrap-Up

Internal Revenue Bulletin

2018-35

Internal Revenue Bulletin of August 27, 2018

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Additional Resources

Ernst & Young Client Portal, the leading source for news, analysis, and reference materials for corporate tax professionals, has a variety of content of interest to international tax practitioners, including:

— International Tax Online Reference Service. Key information about, and important tax developments from, 56 foreign jurisdictions, including information on tax rates, interest rates and penalties, withholding, and filing dates.

— EY/Passport. EY/Passport is your guide to planning ventures in the global economy, offering a wealth of tax and business knowledge on more than 150 countries.

Because the matters covered herein are complicated, U.S. International Tax This Week should not be regarded as offering a complete explanation and should not be used for making decisions. Any decision concerning matters covered herein should be reviewed with a qualified tax advisor.

Document ID: 2018-1685