Daily Tax Update - December 14, 2017: Negotiations Continue on Tax Reform Package

Negotiations Continue on Tax Reform Package:  Republicans continue to work on the Tax Reform and Jobs Act conference agreement.

IRS Rules on Alternative Fuel Mixtures:  Today, the IRS issued Revenue Ruling 2018-02 which addresses whether mixtures of butane and gasoline are alternative fuel mixtures for purposes of the alternative fuel mixture credit under section 6426(e). The IRS determined that a mixture of butane (or other gasoline blendstock as defined in section 48.4081-1(c)(3)(i)) and gasoline is a mixture of two taxable fuels, is not an alternative fuel mixture, and therefore does not qualify for the alternative fuel mixture credit under section 6426(e).

Coca-Cola Wins on Foreign Tax Credit Claim in Tax Court:  Today, the US Tax Court issued an opinion on a motion for summary judgment regarding Coca-Cola’s ability to claim foreign tax credits for income taxes paid to Mexico. The Tax Court held that the calculation of Mexican tax paid was made under a reasonable interpretation of Mexican law, and until and unless Coca-Cola’s correlative US tax liability is adjusted, Coca-Cola has exhausted all effective and practical remedies to reduce its liability for Mexican tax and such taxes were compulsory. Trial with respect to transfer pricing adjustments  is  scheduled for March 2018.

IRS Issues Statement on 2018 Withholding Guidance:  Today, the IRS issued a statement that it is monitoring the pending tax legislation in Congress and anticipates issuing the initial withholding guidance in January 2018 reflecting the new legislation.