Overview
Treasury Submits Proposed Section 956 Regulations: Today, the Department of the Treasury and the Internal Revenue Service submitted proposed regulations to the Office of the Federal Register that would revise the rules relating to investments in US property under section 956 to reflect changes made last year in P.L. 115-97. Treasury and the IRS have determined that, following the enactment of the participation exemption system set out in section 245A, a broad application of section 956 to corporate US shareholders would be inconsistent with the purposes of section 956 and the scope of transactions it is intended to address. The proposed regulations therefore would exclude corporate US shareholders from the application of section 956 to the extent necessary to maintain symmetry between the taxation of actual repatriations and the taxation of effective repatriations.
Brady Comments on UK Digital Services Tax: Today, House Ways and Means Committee Chairman Kevin Brady (R-TX) issued a statement on the UK’s proposed new digital services tax (click here for prior coverage). Calling the new tax “troubling,” Brady stated that the UK’s actions “will prompt a review of our US tax and regulatory approach to determine what actions are appropriate to ensure a level playing field in global markets.”
OECD Publishes Report on Revenue Trends in Africa: The OECD released its third edition of “Revenue Statistics in Africa,” its report on internationally comparable data on both tax and non-tax revenues for 21 African countries. The report found that Africa sustained the gains in domestic resource mobilization made since 2000, as tax revenues remained stable in 2016.