US: Proposed 956 regulations would limit foreign tax credit planning by reducing Section 956 inclusions for corporate US shareholders
|
|
- Amber Goodman
- 5 years ago
- Views:
Transcription
1 5 November 2018 Global Tax Alert US: Proposed 956 regulations would limit foreign tax credit planning by reducing Section 956 inclusions for corporate US shareholders NEW! EY Tax News Update: Global Edition EY s new Tax News Update: Global Edition is a free, personalized subscription service that allows you to receive EY Global Tax Alerts, newsletters, events, and thought leadership published across all areas of tax. Access more information about the tool and registration here. Also available is our EY Global Tax Alert Library on ey.com. On 31 October 2018, the United States (US) Treasury Department (Treasury) and the Internal Revenue Service (IRS) issued proposed regulations under Internal Revenue Code 1 Section 956 (the Proposed 956 Regulations) that would, in certain cases, reduce an inclusion under Section 956 (a Section 956 inclusion) to corporate US shareholders of certain controlled foreign corporations (a CFC). In general, the reduction to the Section 956 inclusion equals the amount of the deduction under Section 245A (a Section 245A deduction) that the corporate US shareholder would have been allowed if the CFC had distributed to the corporate US shareholder an amount equal to the potential Section 956 inclusion. Rules are provided to address indirectly-owned CFCs. The Proposed 956 Regulations do not apply to non-corporate US shareholders. The Proposed 956 Regulations apply to tax years of a CFC beginning on or after the date final regulations are published in the Federal Register. Taxpayers may, however, rely on the Proposed 956 Regulations for tax years of a CFC beginning after 31 December 2017, and before the date final regulations are published, provided that the taxpayer and its related US persons consistently apply the Proposed 956 Regulations to all of their CFCs.
2 2 Global Tax Alert Background A US shareholder (whether or not a corporation) of a CFC generally must include in gross income an amount determined under Section 956. This Section 956 amount generally corresponds to the amount of United States property held by a CFC but only to the extent of applicable earnings an amount that thereby is deemed to have been repatriated. In connection with the inclusion, a corporate US shareholder is deemed to have paid (and generally may take as a credit against its US federal income tax liability) certain foreign income taxes actually paid by the CFC and properly attributable to the Section 956 inclusion. Section 245A allows domestic corporations a deduction upon receipt of an eligible dividend from a qualifying foreign corporation. In general, a domestic corporation may not claim a credit for taxes paid or accrued with respect to a dividend for which a deduction is allowed under Section 245A. Detailed discussion of Proposed 956 Regulations Reduction of inclusion under Section 956 In general The Proposed 956 Regulations reduce a corporate US shareholder s Section 956 amount when a hypothetical distribution from the CFC would have resulted in a dividend eligible for a deduction under Section 245A. Determination of the reduction is made on a share-by-share (of the CFC) basis and encompasses two steps. First, the tentative Section 956 amount for each share that the corporate US shareholder owns (within the meaning of Section 958(a)) in the CFC is determined under existing rules. Second, the tentative Section 956 amount is reduced by the amount of the Section 245A deduction that the corporate US shareholder would be allowed based on a hypothetical distribution of an amount equal to the tentative Section 956 amount from the CFC for each share. Although neither expressly noted in the Proposed 956 Regulations nor in the preamble, the Proposed 956 Regulations will likely hinder taxpayers ability to affirmatively use Section 956 to repatriate earnings with foreign taxes properly attributable to such earnings. Indirect ownership rules The Proposed 956 Regulations describe rules applicable when a US shareholder owns shares of the CFC indirectly (within the meaning of Section 958(a)(2)). Unless the hypothetical distribution is subject to Section 245A(e) which provides special rules for hybrid dividends, the hypothetical distribution is generally treated for purposes of Sections 245A, 246(a) and 959 as if the corporate US shareholder directly owned the CFC. To determine if the hypothetical distribution is considered a hybrid dividend (within the meaning of Section 245A(e)), the distribution is treated as if it were made to the US shareholder through each intermediary entity. To the extent Section 245A(e)(2) would apply, then the US shareholder is treated as not being allowed a deduction under Section 245A by reason of the hypothetical distribution. Applicable to corporate US shareholder The Proposed 956 Regulations apply solely to domestic corporations. As explained in the preamble, US individuals do not qualify for the dividend received deduction of Section 245A, even if a Section 962 election to treat an individual as a corporation for purposes of Sections 951(a) and 960 is made. The preamble requests comments on US partnerships that are US shareholders of CFCs. Authority and request for comments The preamble states that the Proposed 956 Regulations are issued under the authority of Sections 7805, 245A(g) and 956(e). More specifically, Section 956(e) grants the Secretary authority to ensure that the application of Section 956 is consistent with its purposes, including establishing symmetrical treatment between actual dividends and other effective repatriations. The preamble cites other instances in which Treasury and the IRS have exercised such authority to ensure that the application of Section 956 is consistent with its purposes. In all those instances, however, the authority has been used to exclude certain property from the definition of US property in Section 956(c). In addition to requesting comments on the application of the proposed rules to domestic partnerships, the preamble requests comments on the maintenance of previously taxed earnings and profits (PTI) accounts under Section 959, basis adjustments under Section 961, and the interaction of the Proposed 956 Regulations with Section 245A(e) (relating to hybrid dividends).
3 Global Tax Alert 3 Implications The Proposed 956 Regulations would allow corporate US shareholders to access cash held by their CFCs more easily in certain fact patterns that would have otherwise resulted in Section 956 inclusions, which are subject to tax at the 21% corporate rate. Allowing taxpayers to currently rely on the Proposed 965 Regulations is also a welcome benefit. The Proposed 956 Regulations are not so welcome news, however, for those taxpayers seeking to affirmatively trigger Section 956 inclusion to access creditable foreign taxes paid by their CFCs, although such planning may still be possible in certain cases because the proposed regulations do not eliminate Section 956 inclusions in all cases. Additionally, the Proposed 956 Regulations largely minimize the effect of Section 956 on common cross-border financial transactions, including US group borrowings from CFCs, and CFC credit support of US third-party borrowings through CFC guarantees/pledges of CFC stock. As a result of the Proposed 956 Regulations, US borrowers may seek to obtain interest rate reductions on existing third-party borrowings by pledging all of their CFC stock or issuing CFC guarantees, or increase liquidity available within existing cash pool structures by adding CFC participants to the arrangement, practices taxpayers generally avoided before the issuance of the Proposed Regulations. Taxpayers must, however, consider any collateral US tax effects before modifying any existing arrangements, including the potential application of Sections 59A (BEAT), 267A (anti-hybrid), and Treas. Reg. Section , as well as any implications such changes may have on the taxpayer s GILTI profile, foreign currency risk management, and withholding tax considerations. Endnote 1. All Section references are to the Internal Revenue Code of 1986, and the regulations promulgated thereunder.
4 Global Tax Alert 4 For additional information with respect to this Alert, please contact the following: Ernst & Young LLP, International Tax Services, Washington, DC Jose Murillo jose.murillo@ey.com Martin Milner martin.milner@ey.com Allen Stenger allen.stenger@ey.com John Morris john.morris@ey.com International Tax Services Global ITS Leader, Jeffrey Michalak, Detroit ITS Director, Americas, Craig Hillier, Boston ITS Markets Leader, Americas, Stephen O Neil, New York National ITS Leader, Jose Murillo, Washington ITS Regional Contacts, Ernst & Young LLP (US) Central Colleen Warner, Chicago Northeast Jonny Lindroos, McLean, VA Southeast Scott Shell, Charlotte, NC Southwest Amy Ritchie, Austin West Sadler Nelson, San Jose, CA Financial Services Chris J Housman, New York Canada Ernst & Young LLP (Canada) Albert Anelli, Montreal
5 EY Assurance Tax Transactions Advisory About EY EY is a global leader in assurance, tax, transaction and advisory services. The insights and quality services we deliver help build trust and confidence in the capital markets and in economies the world over. We develop outstanding leaders who team to deliver on our promises to all of our stakeholders. In so doing, we play a critical role in building a better working world for our people, for our clients and for our communities. EY refers to the global organization, and may refer to one or more, of the member firms of Ernst & Young Global Limited, each of which is a separate legal entity. Ernst & Young Global Limited, a UK company limited by guarantee, does not provide services to clients. For more information about our organization, please visit ey.com EYGM Limited. All Rights Reserved. EYG no Gbl NY ED None This material has been prepared for general informational purposes only and is not intended to be relied upon as accounting, tax, or other professional advice. Please refer to your advisors for specific advice. ey.com
US proposed GILTI regulations implement international tax reform changes
17 September 2018 Global Tax Alert US proposed GILTI regulations implement international tax reform changes NEW! EY Tax News Update: Global Edition EY s new Tax News Update: Global Edition is a free, personalized
More informationUS Treasury grants another extension of time for reporting signature authority (FBAR, Form 114) over certain foreign financial accounts
12 December 2018 Global Tax Alert US Treasury grants another extension of time for reporting signature authority (FBAR, Form 114) over certain foreign financial accounts NEW! EY Tax News Update: Global
More informationUS DC Circuit rejects per se bar on bearer shares under Section 883 income exclusion for international shipping and aircraft corporations
21 August 2018 Global Tax Alert US DC Circuit rejects per se bar on bearer shares under Section 883 income exclusion for international shipping and aircraft corporations NEW! EY Tax News Update: Global
More informationExecutive summary. NEW! EY Tax News Update: Global Edition
21 January 2019 Global Tax Alert US federal income tax considerations for taxpayers and QBUs using the Argentine peso as their functional currency and for certain Argentine pesodenominated transactions
More informationUpdated 2019 US Section 1256 qualified board or exchange list
31 January 2019 Global Tax Alert Updated 2019 US Section 1256 qualified board or exchange list NEW! EY Tax News Update: Global Edition EY s new Tax News Update: Global Edition is a free, personalized email
More informationUS IRS concludes gain recognition agreements and related filings not affected by short tax years
30 November 2017 Global Tax Alert US IRS concludes gain recognition agreements and related filings not affected by short tax years EY Global Tax Alert Library Access both online and pdf versions of all
More informationUpdated US list of foreign currency futures contracts starting point for Section 1256
31 January 2019 Global Tax Alert Updated US list of foreign currency futures contracts starting point for Section 1256 NEW! EY Tax News Update: Global Edition EY s new Tax News Update: Global Edition is
More informationUS IRS issues examination guidelines on Form 1120-F filing deadline waivers
2 March 2018 Global Tax Alert US IRS issues examination guidelines on Form 1120-F filing deadline waivers EY Global Tax Alert Library Access both online and pdf versions of all EY Global Tax Alerts. Copy
More informationUS: Forthcoming proposed regulations will offer some clarity on Section 163(j) business interest expense limitation
9 April 2018 Global Tax Alert US: Forthcoming proposed regulations will offer some clarity on Section 163(j) business interest expense limitation EY Global Tax Alert Library Access both online and pdf
More informationUS IRS suspends application of new Section 1446(f) withholding requirement on dispositions of publicly traded partnership interests
12 January 2018 Global Tax Alert US IRS suspends application of new Section 1446(f) withholding requirement on dispositions of publicly traded partnership interests EY Global Tax Alert Library Access both
More informationUS Tax Cuts and Jobs Act significantly affects US private companies with outbound investments
5 February 2018 Global Tax Alert US Tax Cuts and Jobs Act significantly affects US private companies with outbound investments EY Global Tax Alert Library Access both online and pdf versions of all EY
More informationChief Counsel Advice concludes that accrued but unpaid interest constitutes an obligation of a US person for purposes of Section 956
11 September 2014 International Tax Alert EY Global Tax Alert Library Access both online and pdf versions of all EY Global Tax Alerts. Copy into your web browser: http://www.ey.com/gl/en/ Services/Tax/International-
More informationUS Treasury intends to delay application of final regulations under Section 987 by one year
4 October 2017 Global Tax Alert US Treasury intends to delay application of final regulations under Section 987 by one year Immediate pre-transition considerations remain for taxpayers EY Global Tax Alert
More informationUS Treasury grants yet another extension of time for reporting signature authority (FBAR, Form 114) over certain foreign financial accounts
11 January 2018 Global Tax Alert US Treasury grants yet another extension of time for reporting signature authority (FBAR, Form 114) over certain foreign financial accounts EY Global Tax Alert Library
More informationExecutive summary. EY Global Tax Alert Library
28 December 2017 Global Tax Alert US proposed regulations may alleviate foreign currency tax asymmetries for CFCS and provide new mark-to-market election for certain foreign currency transactions EY Global
More informationExecutive summary. EY Global Tax Alert Library
13 December 2016 International Tax Alert US Notice 2016-73 announces amendments to Section 367 regulations applying to certain cross-border triangular reorganizations and inbound nonrecognition transactions
More informationExecutive summary. Detailed discussion. EY Global Tax Alert Library
22 December 2016 International Tax Alert US final regulations retroactively eliminate Section 367(d) s exception for foreign goodwill and going concern value and narrow Section 367(a) s active trade or
More informationUS IRS issues interim guidance under new Section 1446(f) for sales of interests in non-publicly traded partnerships
12 April 2018 Global Tax Alert US IRS issues interim guidance under new Section 1446(f) for sales of interests in non-publicly traded partnerships EY Global Tax Alert Library Access both online and pdf
More informationUS Tax Court holds US parent s CFCs held US Property under Section 956 as result of intercompany transactions
2 August 2017 Global Tax Alert US Tax Court holds US parent s CFCs held US Property under Section 956 as result of intercompany transactions EY Global Tax Alert Library Access both online and pdf versions
More informationUS Section 871(m) final and temporary regulations address dividend equivalents
30 January 2017 International Tax Alert US Section 871(m) final and temporary regulations address dividend equivalents EY Global Tax Alert Library Access both online and pdf versions of all EY Global Tax
More informationCertain growing activities qualify as production activities for purposes of foreign base company sales income rules
23 October 2013 International Tax Alert Certain growing activities qualify as production activities for purposes of foreign base company sales income rules Executive summary On 21 October 2013, the Internal
More informationExecutive summary. EY Global Tax Alert Library
30 January 2017 International Tax Alert US temporary and proposed regulations deny nonrecognition treatment to contributions of appreciated property by US persons to certain partnerships with related foreign
More informationIRS rules on effect of Section 302(a) redemption on post E&P and foreign income tax pools
8 November 2013 International Tax Alert IRS rules on effect of Section 302(a) redemption on post- 1986 E&P and foreign income tax pools Executive summary On 30 September 2013, the Internal Revenue Service
More informationUS international tax provisions and implications of the Tax and Jobs Act
6 November 2017 Global Tax Alert US international tax provisions and implications of the Tax and Jobs Act EY Global Tax Alert Library Access both online and pdf versions of all EY Global Tax Alerts. Copy
More informationUS IRS and Treasury issue guidance offering RICs with Section 853 elections alternative methods for handling foreign tax refunds
22 January 2016 International Tax Alert US IRS and Treasury issue guidance offering RICs with Section 853 elections alternative methods for handling foreign tax refunds EY Global Tax Alert Library Access
More informationUS IRS issues proposed regulations. and registered form rules. Executive summary. Detailed discussion. EY Global Tax Alert Library.
25 September 2017 Global Tax Alert US IRS issues proposed regulations on registrationrequired obligations and registered form rules EY Global Tax Alert Library Access both online and pdf versions of all
More informationUS IRS guidance offers relief for financial institutions required to obtain and report taxpayer identification numbers
2 October 2017 Global Tax Alert US IRS guidance offers relief for financial institutions required to obtain and report taxpayer identification numbers EY Global Tax Alert Library Access both online and
More informationUS IRS issues proposed regulations on international rules under BBA partnership audit regime
7 December 2017 Global Tax Alert US IRS issues proposed regulations on international rules under BBA partnership audit regime EY Global Tax Alert Library Access both online and pdf versions of all EY Global
More informationExecutive summary. EY Global Tax Alert Library
13 December 2016 International Tax Alert Final and temporary US foreign currency regulations change determination of branch taxable income and recognition of Section 987 gain or loss and defer Section
More informationUS Tax Court refuses to follow IRS guidance subjecting foreign investors to US tax on dispositions of partnership investments
20 July 2017 Global Tax Alert US Tax Court refuses to follow IRS guidance subjecting foreign investors to US tax on dispositions of partnership investments EY Global Tax Alert Library Access both online
More informationUS IRS releases proposed Qualified Intermediary Agreement
7 July 2016 International Tax Alert US IRS releases proposed Qualified Intermediary Agreement EY Global Tax Alert Library Access both online and pdf versions of all EY Global Tax Alerts. Copy into your
More informationUS IRS concludes subsidiary not eligible for dividends received deduction as transaction lacked economic substance
11 October 2016 International Tax Alert US IRS concludes subsidiary not eligible for dividends received deduction as transaction lacked economic substance EY Global Tax Alert Library Access both online
More informationIRS notes in AM that US shareholder must increase earnings and profits in the year of a Section 951(a)(1) inclusion
20 February 2015 International Tax Alert EY Global Tax Alert Library Access both online and pdf versions of all EY Global Tax Alerts. Copy into your web browser: http://www.ey.com/gl/en/ Services/Tax/International-
More informationUS regulations forthcoming on partnership nonrecognition of property contributions
19 August 2015 International Tax Alert EY Global Tax Alert Library Access both online and pdf versions of all EY Global Tax Alerts. Copy into your web browser: http://www.ey.com/gl/en/ Services/Tax/International-
More informationIRS rules consent fee paid on contingent payment debt instrument may result in a taxable exchange
13 August 2014 International Tax Alert EY Global Tax Alert Library Access both online and pdf versions of all EY Global Tax Alerts. Copy into your web browser: http://www.ey.com/gl/en/ Services/Tax/International-
More informationTreasury and IRS finalize regulations under Section 909 foreign tax credit splitting events
13 February 2015 International Tax Alert EY Global Tax Alert Library Access both online and pdf versions of all EY Global Tax Alerts. Copy into your web browser: http://www.ey.com/gl/en/ Services/Tax/International-
More informationUS IRS and Treasury amend FIRPTA regulations to reflect PATH Act
23 February 2016 International Tax Alert US IRS and Treasury amend FIRPTA regulations to reflect PATH Act EY Global Tax Alert Library Access both online and pdf versions of all EY Global Tax Alerts. Copy
More informationInternational Tax Alert
30 April 2014 International Tax Alert EY Global Tax Alert Library Access both online and pdf versions of all EY Global Tax Alerts. Copy into your web browser: http://www.ey.com/gl/en/ Services/Tax/International-
More informationUS Tax Cuts and Jobs Act and its impact on technology sector
26 December 2017 Global Tax Alert US Tax Cuts and Jobs Act and its impact on technology sector EY Global Tax Alert Library Access both online and pdf versions of all EY Global Tax Alerts. Copy into your
More informationUpdated 2016 US IRC Section 1256 qualified board or exchange list
25 January 2016 International Tax Alert Updated 2016 US IRC Section 1256 qualified board or exchange list EY Global Tax Alert Library Access both online and pdf versions of all EY Global Tax Alerts. Copy
More informationIRS applies Section 904(f) recapture exception to intercompany asset transfer preceding deconsolidation of transferee member
12 January 2015 International Tax Alert EY Global Tax Alert Library Access both online and pdf versions of all EY Global Tax Alerts. Copy into your web browser: http://www.ey.com/gl/en/ Services/Tax/International-
More informationIRS issues final, temporary and proposed regulations on determining PFIC ownership and annual filing requirements for PFIC shareholders
10 January 2014 International Tax Alert EY Global Tax Alert Library Access both online and pdf versions of all EY Global Tax Alerts. Copy into your web browser: http://www.ey.com/gl/en/ Services/Tax/International-
More informationUS Senator Levin introduces bill to tighten inversion rules under Section 7874
2 June 2014 International Tax Alert EY Global Tax Alert Library Access both online and pdf versions of all EY Global Tax Alerts. Copy into your web browser: http://www.ey.com/gl/en/ Services/Tax/International-
More informationTreasury and IRS plan to change rules for claiming refunds and credits for certain withholding taxes
4 May 2015 International Tax Alert EY Global Tax Alert Library Access both online and pdf versions of all EY Global Tax Alerts. Copy into your web browser: http://www.ey.com/gl/en/ Services/Tax/International-
More informationTreasury and IRS issues guidance on 2% tax on payments US government makes to foreign persons under certain contracts
27 April 2015 International Tax Alert EY Global Tax Alert Library Access both online and pdf versions of all EY Global Tax Alerts. Copy into your web browser: http://www.ey.com/gl/en/ Services/Tax/International-
More informationIRS updates procedures for withholding foreign partnerships and withholding foreign trusts; coordinates rules with FATCA
15 August 2014 International Tax Alert EY Global Tax Alert Library Access both online and pdf versions of all EY Global Tax Alerts. Copy into your web browser: http://www.ey.com/gl/en/ Services/Tax/International-
More informationIRS issues instructions to Form W-8BEN-E
30 June 2014 International Tax Alert EY Global Tax Alert Library Access both online and pdf versions of all EY Global Tax Alerts. Copy into your web browser: http://www.ey.com/gl/en/ Services/Tax/International-
More informationUS IRS issues Section 871(m) transition rules
9 December 2016 International Tax Alert US IRS issues Section 871(m) transition rules EY Global Tax Alert Library Access both online and pdf versions of all EY Global Tax Alerts. Copy into your web browser:
More informationInternational Tax Alert. Executive summary
19 May 2015 International Tax Alert EY Global Tax Alert Library Access both online and pdf versions of all EY Global Tax Alerts. Copy into your web browser: http://www.ey.com/gl/en/ Services/Tax/International-
More informationUS IRS is focusing on FATCA Intergovernmental Agreements currently in effect
8 August 2016 International Tax Alert US IRS is focusing on FATCA Intergovernmental Agreements currently in effect EY Global Tax Alert Library Access both online and pdf versions of all EY Global Tax Alerts.
More informationIRS issues instructions for requester of Forms W-8BEN, W-8BEN-E, W-8ECI, W-8EXP, and W-8IMY
28 July 2014 International Tax Alert EY Global Tax Alert Library Access both online and pdf versions of all EY Global Tax Alerts. Copy into your web browser: http://www.ey.com/gl/en/ Services/Tax/International-
More informationUS IRS issues FAA F recharacterizing intercompany referral fee income and reallocating intercompany referral fee expenses
26 August 2015 International Tax Alert EY Global Tax Alert Library Access both online and pdf versions of all EY Global Tax Alerts. Copy into your web browser: http://www.ey.com/gl/en/ Services/Tax/International-
More informationUS House tax reform bill would significantly affect life sciences sector
13 November 2017 Global Tax Alert US House tax reform bill would significantly affect life sciences sector EY Global Tax Alert Library Access both online and pdf versions of all EY Global Tax Alerts. Copy
More informationA deeper look at forthcoming US Treasury regulations affecting certain inversion transactions
4 December 2015 International Tax Alert A deeper look at forthcoming US Treasury regulations affecting certain inversion transactions EY Global Tax Alert Library Access both online and pdf versions of
More informationTemporary regulations issued regarding treatment of certain stock of a foreign corporation under Section 7874
23 January 2014 International Tax Alert EY Global Tax Alert Library Access both online and pdf versions of all EY Global Tax Alerts. Copy into your web browser: http://www.ey.com/gl/en/ Services/Tax/International-
More informationUS tax reform: A guide to income tax accounting considerations
20 December 2017 Global Tax Alert US tax reform: A guide to income tax accounting considerations EY Global Tax Alert Library Access both online and pdf versions of all EY Global Tax Alerts. Copy into your
More informationUnited States and Vietnam sign first income tax treaty
15 July 2015 International Tax Alert EY Global Tax Alert Library Access both online and pdf versions of all EY Global Tax Alerts. Copy into your web browser: http://www.ey.com/gl/en/ Services/Tax/International-
More informationFY 2016 Budget international tax proposals have implications for inbound investors
17 February 2015 International Tax Alert EY Global Tax Alert Library Access both online and pdf versions of all EY Global Tax Alerts. Copy into your web browser: http://www.ey.com/gl/en/ Services/Tax/International-
More informationCanada: Nunavut issues budget
30 May 2018 Global Tax Alert News from Americas Tax Center Canada: Nunavut issues budget 2018-19 NEW! EY Tax News Update: Global Edition EY s new Tax News Update: Global Edition is a free, personalized
More informationThird Circuit US Court of Appeals holds UK windfall profits tax not a creditable income tax for US foreign tax credit purposes
5 January 2012 International Tax Alert Get the world to go! You can access corporate income tax rates of over 65 countries for multiple years using your mobile device: Type into your web browser: www.ey.mobi/its/rates
More informationReport released by top US Senate Finance Committee Republican calls for international tax reform
22 December 2014 International Tax Alert EY Global Tax Alert Library Access both online and pdf versions of all EY Global Tax Alerts. Copy into your web browser: http://www.ey.com/gl/en/ Services/Tax/International-
More informationUS Senate Finance Committee Chairman s Mark of the Tax Cuts and Jobs Act: Energy sector implications
14 November 2017 Global Tax Alert US Senate Finance Committee Chairman s Mark of the Tax Cuts and Jobs Act: Energy sector implications EY Global Tax Alert Library Access both online and pdf versions of
More informationNew anti-base erosion and anti-inversion international tax proposals included in the Administration s fiscal year 2015 Budget
28 March 2014 International Tax Alert EY Global Tax Alert Library Access both online and pdf versions of all EY Global Tax Alerts. Copy into your web browser: http://www.ey.com/gl/en/ Services/Tax/International-
More informationHong Kong-India income tax treaty enters into force
6 December 2018 Global Tax Alert Hong Kong-India income tax treaty enters into force NEW! EY Tax News Update: Global Edition EY s new Tax News Update: Global Edition is a free, personalized email subscription
More informationIndonesia releases amendments to the anti-tax treaty abuse rules
6 December 2018 Global Tax Alert Indonesia releases amendments to the anti-tax treaty abuse rules NEW! EY Tax News Update: Global Edition EY s new Tax News Update: Global Edition is a free, personalized
More informationUK publishes draft Finance Bill clauses and other documents
9 July 2018 Global Tax Alert UK publishes draft Finance Bill clauses and other documents NEW! EY Tax News Update: Global Edition EY s new Tax News Update: Global Edition is a free, personalized email subscription
More informationIRS issues guidance on treatment under Sections 482 and 901 of transactions with foreign branches or disregarded entities
12 December 2013 International Tax Alert News from Transfer Pricing EY Global Tax Alert Library Access both online and pdf versions of all EY Global Tax Alerts. Copy into your web browser: http://www.ey.com/gl/en/
More informationWhat you need to know about the final FFI Agreement
3 January 2014 International Tax Alert EY Global Tax Alert Library Access both online and pdf versions of all EY Global Tax Alerts. Copy into your web browser: http://www.ey.com/gl/en/ Services/Tax/International-
More informationIRS rules on application of manufacturing exception where sales activities did not include taking of title
1 July 2013 IRS rules on application of manufacturing exception where sales activities did not include taking of title Executive summary In a private letter ruling (PLR 201325005), the Internal Revenue
More informationLuxembourg-Cyprus double tax treaty enters into force
7 June 2018 Global Tax Alert Luxembourg-Cyprus double tax treaty enters into force NEW! EY Tax News Update: Global Edition EY s new Tax News Update: Global Edition is a free, personalized email subscription
More informationUS Treasury Department releases 2016 US Model Treaty including new provisions to combat base erosion and profit shifting
26 February 2016 International Tax Alert US Treasury Department releases 2016 US Model Treaty including new provisions to combat base erosion and profit shifting EY Global Tax Alert Library Access both
More informationUK s bilateral APA program for financial transactions is in line with growing global approach
5 November 2018 Global Tax Alert News from Transfer Pricing UK s bilateral APA program for financial transactions is in line with growing global approach NEW! EY Tax News Update: Global Edition EY s new
More informationCFC income from software leases determined to be foreign personal holding company income
18 July 2013 CFC income from software leases determined to be foreign personal holding company income Executive summary On 15 July 2013, the Internal Revenue Service (the Service) released Field Attorney
More informationOECD releases the United States peer review report on implementation of BEPS Action 14 minimum standards
2 October 2017 Global Tax Alert OECD releases the United States peer review report on implementation of BEPS Action 14 minimum standards EY Global Tax Alert Library Access both online and pdf versions
More informationUK publishes response to consultation on corporate intangible fixed assets regime and draft legislation
14 November 2018 Global Tax Alert UK publishes response to consultation on corporate intangible fixed assets regime and draft legislation NEW! EY Tax News Update: Global Edition EY s new Tax News Update:
More informationSpain releases draft bill on Digital Services Tax
25 October 2018 Indirect Tax Alert Spain releases draft bill on Digital Services Tax NEW! EY Tax News Update: Global Edition EY s new Tax News Update: Global Edition is a free, personalized email subscription
More informationBelgium introduces 100% participation exemption
20 March 2018 Global Tax Alert Belgium introduces 100% participation exemption EY Global Tax Alert Library Access both online and pdf versions of all EY Global Tax Alerts. Copy into your web browser: www.ey.com/taxalerts
More informationHong Kong and India sign income tax treaty
28 March 2018 Global Tax Alert Hong Kong and India sign income tax treaty EY Global Tax Alert Library Access both online and pdf versions of all EY Global Tax Alerts. Copy into your web browser: www.ey.com/taxalerts
More informationFrench Government submits draft bill on digital services tax to Council of Ministers
8 March 2019 Indirect Tax Alert French Government submits draft bill on digital services tax to Council of Ministers NEW! EY Tax News Update: Global Edition EY s new Tax News Update: Global Edition is
More informationCanada: Yukon issues budget
28 April 2017 Global Tax Alert News from Americas Tax Center Canada: Yukon issues budget 2017-18 EY Global Tax Alert Library The EY Americas Tax Center brings together the experience and perspectives of
More informationUS Tax Cuts and Jobs Act and its impact on the energy sector
29 December 2017 Global Tax Alert US Tax Cuts and Jobs Act and its impact on the energy sector EY Global Tax Alert Library Access both online and pdf versions of all EY Global Tax Alerts. Copy into your
More informationIreland s Country-by- Country reporting notification deadline is 31 December 2016
12 December 2016 Global Tax Alert News from Transfer Pricing Ireland s Country-by- Country reporting notification deadline is 31 December 2016 EY Global Tax Alert Library Access both online and pdf versions
More informationUS IRS limits use of mandatory transfer pricing IDR and instructs examiners on penalties in transfer pricing cases
24 January 2018 Global Tax Alert News from Transfer Pricing US IRS limits use of mandatory transfer pricing IDR and instructs examiners on penalties in transfer pricing cases EY Global Tax Alert Library
More informationHong Kong releases new practice note on concessionary tax regime for qualifying aircraft leasing activities
10 November 2017 Global Tax Alert Hong Kong releases new practice note on concessionary tax regime for qualifying aircraft leasing activities EY Global Tax Alert Library Access both online and pdf versions
More informationPuerto Rico extends automatic extension period for filing a 2017 tax return from three months to six months
17 April 2018 Global Tax Alert News from Americas Tax Center Puerto Rico extends automatic extension period for filing a 2017 tax return from three months to six months EY Global Tax Alert Library The
More informationDenmark publishes draft bill to implement EU ATAD
5 June 2018 Global Tax Alert Denmark publishes draft bill to implement EU ATAD NEW! EY Tax News Update: Global Edition EY s new Tax News Update: Global Edition is a free, personalized email subscription
More informationCanada: Prince Edward Island issues budget
10 April 2018 Global Tax Alert News from Americas Tax Center Canada: Prince Edward Island issues budget 2018-19 EY Global Tax Alert Library The EY Americas Tax Center brings together the experience and
More informationPanama s Minister of Economy and Finance proposes bill for calculating income subject to preferential tax treatment under an IP regime
28 August 2018 Global Tax Alert News from Americas Tax Center Panama s Minister of Economy and Finance proposes bill for calculating income subject to preferential tax treatment under an IP regime NEW!
More informationCanada: Ontario Ministry of Finance seeks input on proposals to facilitate compliance with the Land Transfer Tax Act
24 July 2017 Indirect Tax Alert News from Americas Tax Center Canada: Ontario Ministry of Finance seeks input on proposals to facilitate compliance with the Land Transfer Tax Act EY Global Tax Alert Library
More informationMauritius issues new rules on substance for GBL and other related changes
19 October 2018 Global Tax Alert Mauritius issues new rules on substance for GBL and other related changes NEW! EY Tax News Update: Global Edition EY s new Tax News Update: Global Edition is a free, personalized
More informationIndonesia releases new tax holidays
13 December 2018 Global Tax Alert Indonesia releases new tax holidays NEW! EY Tax News Update: Global Edition EY s new Tax News Update: Global Edition is a free, personalized email subscription service
More informationJordan amends Income Tax Law
27 December 2018 Global Tax Alert Jordan amends Income Tax Law NEW! EY Tax News Update: Global Edition EY s new Tax News Update: Global Edition is a free, personalized email subscription service that allows
More informationOECD launches International Compliance Assurance Programme pilot
26 January 2018 Global Tax Alert OECD launches International Compliance Assurance Programme pilot EY Global Tax Alert Library Access both online and pdf versions of all EY Global Tax Alerts. Copy into
More informationUK CFC rules: European Commission publishes opening decision on State aid
20 November 2017 Global Tax Alert UK CFC rules: European Commission publishes opening decision on State aid EY Global Tax Alert Library Access both online and pdf versions of all EY Global Tax Alerts.
More informationIndian Tax Administration issues draft indirect transfer rules
26 May 2016 Global Tax Alert Indian Tax Administration issues draft indirect transfer rules EY Global Tax Alert Library Access both online and pdf versions of all EY Global Tax Alerts. Copy into your web
More informationLuxembourg publishes draft law ratifying Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS
4 September 2018 Global Tax Alert Luxembourg publishes draft law ratifying Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS NEW! EY Tax News Update: Global Edition EY s
More informationTurkey amends transfer pricing legislation
19 August 2016 Global Tax Alert News from Transfer Pricing Turkey amends transfer pricing legislation EY Global Tax Alert Library Access both online and pdf versions of all EY Global Tax Alerts. Copy into
More informationCanada: British Columbia introduces employer health tax legislation
25 October 2018 Indirect Tax Alert News from Americas Tax Center Canada: British Columbia introduces employer health tax legislation NEW! EY Tax News Update: Global Edition EY s new Tax News Update: Global
More informationSaint Lucia complies with its international commitments while maintaining its attractiveness to investors
12 December 2018 Global Tax Alert Saint Lucia complies with its international commitments while maintaining its attractiveness to investors NEW! EY Tax News Update: Global Edition EY s new Tax News Update:
More informationCanada amends taxation of investment income earned through a private corporation
14 December 2015 Global Tax Alert News from Americas Tax Center Canada amends taxation of investment income earned through a private corporation EY Global Tax Alert Library The EY Americas Tax Center brings
More information