Strategizing Multinational Tax Risks

Treasury is now fairly confident that all TCJA guidance will be finalized by October 1st.

Treasury deputy assistant secretary for international tax affairs, Lafayette G. “Chip” Harter III, recently shared his ambitious agenda, including the following:

• Section 901(m) regulations, imminent
• Section 163(j) interest, OIRA received proposed regulations February 7th; final reg review is complete
• FDII regulations, spring; documentation requirements have been reworked
• GILTI regulations, summer
• Foreign tax credit regulations and others, in the pipeline

• Treaties with Chile, Hungary and Poland; may be reworked, as there are concerns that the BEAT violates Articles 23 (relief from double taxation) and 24 (nondiscrimination) of the U.S. model income tax treaty