Strategizing Multinational Tax Risks

Tax changes are continuing, both from prior and proposed legislation on several fronts:

• “Phase 2” tax reform bill to be released next week; House vote Sept, mid-term Nov elections may be an obstacle
• Proposed regulations for Section 965 Tax Act guidance now in review, issuance this fall
• Guidance for GILTI, FDII and BEAT to be issued this fall; a consolidated approach is likely for GILTI and BEAT
• Country-by-Country (CbC) reports are being reviewed for risk profiles
• States are continuing to issue prospective, and retroactive, guidance on Sec. 965 and  the new 2018 Tax Act provisions

The EY Global Tax Alert provides additional details of the above points for reference:

Click to access 2018G_010372-18Gbl_Report%20on%20recent%20US%20international%20tax%20developments%20-%2020%20July%202018.pdf