On Friday, June 14, the U.S. Treasury Department and Internal Revenue Service issued several guidance packages that continue to implement the international tax provisions introduced by the 2017 U.S. tax law (often referred to as the Tax Cuts and Jobs Act or TCJA). The guidance packages include:
- Final regulations relating to section 951A and “global intangible low-taxed income” (GILTI) provisions, as well as various foreign tax credit and section 965 provisions
- Temporary regulations providing anti-abuse rules under section 245A
- Proposed regulations concerning the treatment of domestic partnerships for purposes of applying sections 951(a) and 951A and providing a “high-tax exception” to the GILTI provisions.
KPMG LLP (KPMG) is pleased to offer a two-hour TaxWatch webcast on these regulations and their potential impact on multinational companies. Professionals from KPMG’s Washington National Tax practice provide:
- An overview of each of the new regulations packages, summarizing key provisions
- A review of what was expected and unexpected in the regulation packages
- Insights on the potential implications for multinational companies and potential initial actions affected companies may want to consider.