Overview
House Passes Omnibus Spending Bill: The House passed the Consolidated Appropriations Act, 2018 on a 256-167 vote. The bill includes a provision, referred to as the “grain glitch fix,” that revises a provision in the 2017 tax legislation that gave farmers a larger deduction for crop sales to agricultural cooperatives than for sales to corporate buyers. The bill also includes a four-year expansion of the low-income housing tax credit that would increase the total credit allocation for calendar years 2018 through 2021 by 12.5 percent and modify the average income test under section 42(g). The bill includes numerous other technical tax corrections relating to:
- Protecting Americans from Tax Hikes Act of 2015
- Consolidated Appropriations Act, 2016
- Fixing America’s Surface Transportation Act
- Surface Transportation and Veterans Health Care Choice Improvement Act of 2015
- Stephen Beck, Jr., ABLE Act of 2014
- American Taxpayer Relief Act of 2012
- Amendment relating to United States-Korea Free Trade Agreement Implementation Act
- SAFETEA–LU
- American Jobs Creation Act of 2004
- Bipartisan Budget Act of 2015 (including with respect to the partnership audit rules)
- Energy Policy Act of 2005
- Other clerical corrections and deadwood-related provisions
OECD Releases Additional Transfer Pricing Guidance: The OECD released a report Additional Guidance on the Attribution of Profits to Permanent Establishments under BEPS Action 7. The report sets out high-level general principles, which countries agree are relevant and applicable in attributing profits to permanent establishments in accordance with applicable treaty provisions. It also provides examples on the attribution of profits to certain types of permanent establishments arising from the changes to the permanent establishment definition under BEPS Action 7.