30 September 2018

U.S. International Tax This Week for September 28

Ernst & Young's U.S. International Tax This Week newsletter for the week ending September 28 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 House this week moved forward on the three bills making up "tax reform 2.0." On 27 September, the House approved the American Innovation Act of 2018 (H.R. 6756) and the Family Savings Act of 2018 (H.R. 6757). As we go to press on 28 September, the House was expected to approve the third tranche of the phase 2 tax reform, the Protecting Family and Small Business Tax Cuts of 2018 (H.R. 6760), to make permanent certain Tax Cuts and Jobs Act (TCJA) provisions. The Ways and Means Committee divided up the tax reform measures into three bills to increase the chance of passage of at least some of the provisions. The Senate is not expected to bring the bills for a floor vote before the November mid-term elections.

An IRS official this week was quoted as saying that the final Global Intangible Low-Taxed Income (GILTI) regulations will be released by June 2019 to enable taxpayers to use the guidance for the entire year. This is the first indication of when the Service plans to finalize the rules. Proposed rules on the interaction of the foreign tax credit regime and GILTI are expected to be released before year-end, the official said.

An IRS official from the Large Business and International Division this week said the Service plans to establish separate webpages for the major international tax provisions enacted by the 2017 tax reform to provide informal taxpayer guidance. The webpages will follow a similar format that was adopted by the IRS to offer informal information regarding the TCJA's transition tax.

The IRS announced it will be restructuring the Advance Pricing and Mutual Agreement program (APMA) to consolidate resources and improve internal processes. Among the noteworthy changes, all APMA teams will consist of both team leaders and economists to ensure optimal involvement by economists in the process. Unless notified otherwise, taxpayers are to assume that existing cases will continue to be handled by their current APMA team.

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Recent Tax Alerts

United States

Asia

Canada & Latin America

Europe

Middle East

Oceania

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IRS Weekly Wrap-Up

Internal Revenue Bulletin

 2018-40Internal Revenue Bulletin of October 1, 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: 2018-1916