The IRS is pursuing many avenues of guidance this year and next, including:
- Proposed rules for US Tax Act Sec. 965 in August 2018, which should be just in time for the 1-year SAB 118 period that ends Q3 for calendar-year taxpayers.
- Proposed rules for Foreign Tax Credit of the US Tax Act in August 2018
- Proposed rules for GILTI in Sept. 2018 (hopefully this will allow consolidated calculation vs. separate shareholder chain rule currently written in the law)
- Proposed rules for BEAT in October 2018
- Other rules should follow in 2019
This guidance will hopefully clarify the above provisions to allow relevant tax planning, based on the certainty of the US Tax Act provisions.
EY’s Global Alert highlights these developments