The US Tax Framework was published Sept. 27, a notable date as this date is also used to mark the timeframe for expensing investments.
The main corporate tax points, and subtleties, include:
- 20% corporate tax rate, but the tax rate and differential for one-time foreign earnings/cash is not specified.
- Minimum tax on foreign profits to “level the playing field”
- Territoriality system, exempting 100% of dividends (although the KPMG linked notes include the point that this is not equivalent to “distributions” thus a complicated Earnings and Profits tracking system may still apply)
- Interest expense will be “limited” (EBITDA/other?)
- R&D credit remains, although Sec. 199 US manufacturing incentive deduction is lost
- Pass-through structures tax rate of 25%
- Corporate AMT is gone.
The President has formally and forcefully announced his continued message for tax reform, as both the House and Senate Committees are now drafting language that will hopefully result in legislation enacted late 2017 or early 2018 with the political complexities / process.
Upon enactment, the US GAAP tax accounting will be complex and required results for public companies in the quarter of enactment. Additionally, the timing for state enactment is also a separate complex issue that will need analysis.
The US Framework is repeatedly attempting to “level the playing field,” now the politicians, journalists, advisors and tax practitioners will all work with a little bit of fact to create a cocoon of fiction by which the impending tax reform can be measured.
Click to access Tax-Framework.pdf
Strategizing Multinational Tax Risks 
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