US Tax Reform

On 1 August 2018 the US Treasury and the IRS released proposed regulations under Section 965 (the Proposed 965 Regulations). The Proposed 965 Regulations provide guidance relating to the ‘toll tax’ due upon the mandatory deemed repatriation of certain deferred foreign earnings.

Join us on Wednesday, August 15, 2018 from 2-3:00 PM EDT for the latest webcast in our Tax reform readiness series.

Join us this Thursday, August 9, 2018 from 2-3:00PM EDT for this special edition webcast in our Tax reform readiness series.

Watch this webcast from the latest in our Tax reform readiness series, held on Wednesday, 8 August 2018.

Watch the replay from this latest webcast in our Tax reform readiness series held on 1 August 2018.

Watch this webcast replay from 25 July, 2018 for the latest in our Tax reform readiness series.

Watch the replay from the latest webcast in our Tax reform readiness series.

Watch the replay from the latest webcast in our Tax reform readiness series.

Watch the replay of the latest in our tax reform readiness webcast series.

Watch the replay from the latest webcast in our Tax reform readiness series.

View the latest webcast in our Tax reform readiness series.

Watch the replay from the latest webcast in our Tax reform readiness series.

Watch the replay from the latest in our tax reform readiness webcast series.

Watch the replay of the latest in our tax reform readiness webcast series.

Watch the latest in our tax reform readiness webcast series for a look at the impact emerging technologies are having on the tax function.

Companies in the U.S. were already sitting on piles of cash before tax reform passed in December 2017. Now, with a strengthening global economy and a tax overhaul that lowers the corporate tax rate from 35 to 21 percent and incentivises U.S. companies to repatriate all their previously untaxed foreign earnings, those piles of cash are poised to grow substantially. Some estimate there may be more than US$330 billion in tax savings for corporations over the next 10 years, not including the trillions of dollars held overseas that may now come home. The big question is: What will companies do with this windfall?

The 2017 tax reform reconciliation act (the Act) is having a substantial impact on US taxpayers. Among the most significant areas of impact are the international tax reform provisions and their interactions with each other. On May 2 we hosted a webcast featuring PwC specialists who discussed some of the key interactions among these provisions. This Insight highlights some of those discussions.

Watch the latest in our tax reform readiness webcast series.

Watch the latest in our tax reform readiness webcast series.

Watch this webcast in PwC’s Tax reform readiness series.

Watch the replay of this webcast from our tax reform readiness series.

The Treasury and the IRS have released Notice 2018-26, signalling intent to issue regulations related to mandatory repatriation (the 'toll tax'). Notice 2018-26 is the third notice issued as part of the transition to a new territorial tax regime under the 2017 Tax Reform Reconciliation Act, also known as the ‘Tax Cuts and Jobs Act.’

If you are a US citizen or resident or have US family members involved in your Canadian business, consider how the recent US tax reform may impact you.

Watch this webcast replay from 4 April 2018 for the latest in our tax reform readiness webcast series.

For the CFO and Corporate Treasurer, US tax reform could affect everything from capital allocation, funding strategies and liquidity management practices to structure and organisation, presenting new opportunities and risks to the prior ways of conducting business. With this in mind, they should therefore act quickly by evaluating the implications to the company and work across the enterprise to compose short and long term strategy and execution plans.

One of the biggest tax stories of recent months has been the sweeping changes being made to the US tax system. It's clear that when the world's biggest economy makes significant tax changes, it's a big deal worldwide, the effects are far-reaching and could affect all of us. What are the implications for policy makers, and what should businesses be aware of?

Watch this webcast replay from Wednesday 7 March 2018 for the latest in our tax reform readiness webcast series.

Any company with a US footprint is potentially impacted by US tax reform, albeit each a bit differently. Our Tax Valuations team (working alongside tax) can assist on a variety of issues which might arise out of these changes, especially with effective tax rate and provisioning modelling, the consequential impacts on deal pricing and debt push-down analysis, and any changes to operating models.

Webcast replay from 28 February 2018 where our panel of specialists discussed what this new legislation means for your global mobility and HR programmes.

The 2017 tax reform reconciliation act - the largest overhaul of the US tax code in 31 years - is already having a substantial impact on US taxpayers, including on operating models and business strategy decisions.

Recordings are now available of all three episodes in our recent series of webcasts focused on the aspects of US tax reform likely to have the biggest impact on European headed multinationals.

We highlight the key changes together with some brief commentary on things that can be done before the end of the year to maximise the benefit of various deductions/exemptions that certain taxpayers or employers may claim.

On 22nd December 2017, the Tax Cuts and Jobs Act, which brings significant changes to the US tax system, was signed by President Trump and has now become law. The legislation impacts the taxation of some executive compensation and a number of employee benefits.

Find out how sweeping changes to the US tax law will impact your company's financial statements.

On Friday 22 December, President Trump signed the tax reform bill (HR 1) into law. The law will lower business and individual tax rates, modernize US international tax rules, and provide the most significant overhaul of the US tax code in more than 30 years.

Congress has given final approval to the House and Senate conference committee agreement on tax reform legislation (HR 1) that will lower business and individual tax rates, modernise US international tax rules, and provide the most significant overhaul of the US tax code in more than 30 years.

When it comes to accounting for tax reform under US GAAP, new questions arise every day. This “frequently asked questions” document shares our views on the most common questions. It covers topics such as accounting for tax reform by non-calendar year ends, asserting indefinite reinvestment in light of tax reform, application of SAB 118, interplay of tax reform with business combinations and goodwill impairments, and other hot topics.

On 15 December, a House and Senate conference committee reached agreement on a final version of tax reform legislation, the ‘Tax Cuts and Jobs Act,’ that would lower business and individual tax rates, modernize US international tax rules, and provide the most significant overhaul of the US tax code in more than 30 years.

Watch a recording of our recent webcast (19 December 2017) to learn more about what the US Senate's tax reform legislation has in store for global companies that do business in the United States.

We highlight some of the key considerations for individuals and employers who interact with the US, and provide some initial guidance on the proposed tax reforms which are likely to come into effect for the 2018 tax year.

To help you assess the financial reporting implications of the US tax reform, we have prepared a summary of the key proposals together with the relevant tax accounting implications under US GAAP.

PwC partners Len Combs and Jennifer Spang discuss the audit considerations associated with US tax reform proposals.

The Senate Finance bill introduces a new tax on ‘global intangible low-taxed income’ and a minimum ‘base erosion and anti-abuse tax’ imposed on certain payments by a US corporation to a foreign related entity.