Strategizing Multinational Tax Risks

The latest US / OECD developments are detailed in the referenced EY Global Tax Alert, highlighting  a potential second tax bill (apart from technical corrections), status on the “Blue Book: by the Congressional Joint Committee on Taxation, Q&A IRS release re: Section 965 including how to pay the first estimate and report on the US federal income tax return, anti-corporate inversion regulations, and OECD’s Interim Report of the OECD/G20 Inclusive Framework on Base Erosion and Profit Shifting (BEPS), titled “Tax Challenges Arising from Digitalisation.”  Additionally, OECD released the third batch of peer reports – Certainly an exciting and challenging time!

There are still many areas of debate and room for reasonable interpretation on major aspects of the US Tax Act, especially as the 2018 provisions of BEAT, FDII and GILTI are not encased within the one-year measurement period of SAB 118.  For companies subject to Q1 reporting, these uncertainties should be aligned with the auditor to avoid last-minute debates for material items.   

Click to access 2018G_01558-181Gbl_Report%20on%20recent%20US%20international%20tax%20developments%20-%2016%20March%202018.pdf