![]() The preamble to the regulations and the regulations themselves comment and provide guidance on certain international issues such as application of the no-negative adjusted taxable income rule and the expanded anti-abuse rule covering intragroup transactions entered into with a principal purpose of affecting a controlled foreign corporation’s (CFC) section 163(j) limitation and limitation on pre-group business interest carryforwards. In January 2021, the Treasury and IRS issued final regulations (TD 9943) covering a number of section 163(j) business interest limitation provisions applicable to foreign corporations and U.S. International tax update IRS and Treasury issue new regulations and other administrative guidance and formsįinal section 163(j) regulations: international provisions What follows is a high-level outline of international tax and transfer pricing updates, guidance and proposals from late 20 to-date. Congress seems to be using the current reform process as an opportunity to correct, refine or clarify issues brought about by the TCJA. tax legislation is being modified to align with certain global standards in the Organization for Economic Cooperation and Development’s (OECD) base erosion and profit shifting (BEPS) provisions. Second, and perhaps for the first time in the history of U.S. The first is the need to finance the proposed infrastructure bill being drafted and debated in Congress as this letter was being written. A number of factors seem to be influencing these sweeping changes. ![]() international tax provisions since the TCJA itself. The second, and more pronounced, theme emerging from 2021 is that the year may be remembered as the beginning of the largest overhaul of the U.S. This may explain the paucity of the TCJA international-related updates in this 2021 year-end tax letter. Treasury Department and the Internal Revenue Service (IRS) have issued most (if not all) of the major pieces of guidance covering the international provisions of the law known as the Tax Cuts and Jobs Act of 2017 (TCJA). The first, and more subtle of the two, is the impression that the U.S. As we look back on the international tax and transfer pricing developments that unfolded during late 20, two underlying themes emerge.
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