Strategizing International Tax Best Practices – by Keith Brockman

Posts tagged ‘PTI’

US developments/OECD toolkit

Recent international tax developments include the following:

  • OECD is progressing on a Digital Strategy, with planned consensus in 2020 (hopefully separate countries will have added patience for a coordinated approach)
  • US Previously Taxed Income (PTI) regulations are due this summer/fall
  • Foreign Account Tax Compliance Act (FATCA) final regulations were issued, effective March 2019 and expanding the definition of “responsible person”
  • India and the US reached agreement to exchange Country-by-Country (CbC) reports, thus alleviating any need to provide separate India CbC reports for US taxpayers
  • OECD released a Beneficial Ownership Toolkit (reference attached) to assist developing countries in identification of ultimate beneficial owners

EY’s Global Tax Alert is also attached for reference.

Click to access beneficial-ownership-toolkit.pdf

Click to access 2019G_000806-19Gbl_Report%20on%20recent%20US%20international%20tax%20developments%20-%2022%20March%202019.pdf

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Tax Risk Management

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US guidance: Ready, set, go!

Alot of guidance is virtually rolling off the press!

  • PTI guidance for year-end financial statements
  • Foreign tax credits, including application of GILTI
  • Section 163(j) interest guidance
  • Proposed regulations on PTI application
  • BEAT
  • Section 250 guidance

The guidance will be complex and lengthy, and it represents only one step towards achieving more certainty into the complex nuances of the US Tax Act.  EY’s Global Tax Alert provides a summary for reference.

Click to access 2018G_011433-18Gbl_Report%20on%20recent%20US%20international%20tax%20developments%20-%2019%20Oct%202018.pdf

Category:

Tax Risk Management

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