The Joint Committee on Taxation has published a valuable reference for expiring tax provisions 2021-2029.
Although the benefits of Sec. 954(c)(6) were recently extended for 5 years, other provisions will be changing in the next few years, absent additional legislation.
https://www.jct.gov/publications/2021/jcx-1-21/
IRS issued new regulations for translation in Sec. 986(c)
The IRS also issued new LB&I guidance addressing computation of Sec. 986(c) computations, attached for reference.
US T.D. 9909, Final Regulations, in coordination with the issuance of proposed regulations, REG-124737-19, addressing Sec. 245A and the exception to subpart F income under Sec. 954(c)(6). The final regulations address extraordinary dispositions and reductions.
The UK will drop its Digital Service Tax (DST) initiative, knowing it would only increase its stimulus by several hundred million dollars , while COVID-19 has set the country back hundreds of billions of dollars in stimulus. It will be interesting how other countries, who have adopted or are thinking about a unilateral DST, will react prior to the OECD Project addressing this in Pillar One.
Proposed and Final Regulations were issued addressing Section 163(j) interest.
Links are attached for reference
nprm_reg_107911_18td_9905_reg_106089_18
Pursuant to Final and Proposed Regulations recently published, the high-tax exception would be a “unitary” election for both GILTI and Subpart F.
The election is made annually, and can apply retroactively to post-TCJA years.
In summary, Treasury has adopted some taxpayer comments favorably, while delivering an unexpected result in their guidance.
EY’s Alert provides additional background, with links to the Regulations.
The Final Reg’s for Section 250, used in FDII and GILTI calculations, have been finalized. These Reg’s are now undergoing analyses in trying to understand the complexities and nuances. Some highlights include:
The Final Reg’s provided additional clarity, although a taxpayer will have to consider if the Proposed Reg’s or Final Reg’s will be favorable for tax years prior to 2021.
EY’s Tax Alert provides additional details, as referenced.
KPMG’s initial observations of the final and proposed BEAT regulations are attached for reference:
KPMG has provided a quick turnaround on the final and proposed Foreign Tax Credit regulations, linked for reference.
Click to access tnf-ftc-initial-impressions-dec3-2019.pdf
Final and proposed Regulations were issued with respect to the Foreign Tax Credit and BEAT. Noting this regulation package collectively amounts to over 650 pages, it will require time and attention to webcasts, etc. to fully understand the breadth of these rules, especially as they may pertain to 2018 and/or 2019.
Click to access reg-105495-19.pdf
Click to access 2019-25744.pdf
Click to access 2019-25745.pdf
Strategizing Multinational Tax Risks 