Strategizing International Tax Best Practices – by Keith Brockman

US int’l update

The US House and Senate have paved the way for the President’s signature on a bill that extends important international tax topics:

  • Subpart F active financing exception – permanent extension
  • 5-year extension of the CFC look-through rule (through 2019)

A summary of the bill is provided in EY’s Global Tax Alert:

Click to access 2015G_CM6082_Report%20on%20recent%20US%20international%20tax%20developments%20-%2018%20December%202015.pdf

Separately, the US has also indicated that regulations should be forthcoming before year-end for the country-by-country (CbC) reporting rules, which is good news for many.

These rules should provide some international tax certainty for US-based companies, notwithstanding the absence of significant reform for the worldwide tax system.

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