Overview
IRS Issues Proposed Regulations on Global Intangible Low-Taxed Income: The IRS issued proposed regulations (REG-104390-18) today. The proposed regulations provide guidance on implementing the new global intangible low-taxed income (GILTI) provisions for certain US persons treated as owning 10% or more of the stock of a foreign corporation.
GILTI Guidance for REITs: Revenue Procedure 2018-48 issued today provides guidance for real estate investment trusts regarding the treatment of certain foreign income inclusions, including inclusions under section 951A of the Internal Revenue Code, for purposes of the 95% gross income qualification test of section 856(c)(2) of the Internal Revenue Code.
Ways & Means Committee Holds Mark-Up of Tax Reform 2.0: Today, the House Ways & Means Committee held a full-committee markup of the Tax Reform 2.0 proposals. In his opening statement, committee Chairman Kevin Brady (R-TX) said that the proposal will lock in the individual and small business tax cuts from the Tax Cuts and Jobs Act to foster certainty for taxpayers and stimulate economic growth.
European Commission Releases VAT Proposal: The European Commission released a proposal to amend VAT Directive 2006/112/EC to introduce the detailed technical measures of the definitive VAT system for the intra-EU business to business (B2B) trade of goods.
OECD Releases Additional Country-by-Country Reporting Guidance: The OECD released additional interpretative guidance today on the implementation of Country-by-Country (CbC) Reporting (BEPS Action 13) as part of its base erosion and profit shifting (BEPS) initiative. The new guidance includes questions and answers on the treatment of dividends received and the number of employees to be reported when multinational enterprises (MNEs) use proportional consolidation in preparing their financial statements.
Israel & Lithuania Ratify Multilateral BEPS Convention: Today, Israel & Lithuania submitted their ratification documents of the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI). The MLI, which was negotiated in November 2016 by over 100 jurisdictions, will implement a series of tax treaty measures to update international tax rules and lessen the opportunity for tax avoidance by multinational enterprises.