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US Tax Reform
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US Tax Reform could give rise to sweeping, complex changes for companies with a US footprint. To help you stay informed, we'll be updating this hub with all the latest comments and analysis as the situation develops. To request access to all the Insights and Resources across the PwC Suite, click the button at the top of the page.
The 2017 tax reform act (the Act) introduced new Code Section 965, which imposes a ‘toll charge’ on mandatory deemed repatriation of certain deferred foreign earnings. The IRS on January 15 released final regulations under Section 965 that retain the overall structure and basic approach of the proposed Section 965 regulations released on August 1, 2018, with modifications.
The IRS has released a set of Questions and Answers (Q&As) that provide guidance on Section 965 reporting and payment requirements for 2018 tax returns, including obligations resulting from amounts included in income for the 2017 tax year.
The final Section 965 regulations, released on January 15, 2019 (and subsequently updated), specify that, for taxpayers that elected to pay their toll tax liability in installments, if a triggering event or acceleration event occurred on or before the date that the final Section 965 regulations are published in the Federal Register, then a transfer agreement to avoid an acceleration event must be filed within 30 days of that publication date in order to be considered timely filed.
Join us Thursday, January 31, 2019 from 2-3:00PM EDT for the latest webcast where we’ll share reactions to the State of the Union address and also talk through PwC’s latest thought leadership, the 2019 Tax Policy Outlook and Top Policy Trends.
The 2018 US midterm elections and partial government shutdown illustrate the intensified ongoing disagreements between the political parties on how to address many issues, including tax policy, healthcare, immigration, and the environment. A key challenge facing the new 116th Congress and President Trump, will be whether bipartisan agreements can be reached to enact significant legislation with a Democrat-controlled House and a Republican-led Senate.
This PwC Tax Insight highlights some of the major considerations in evaluating the impact of certain federal provisions and notes the need for separate state calculations for many federal tax reform matters.
Treasury has released proposed regulations (the Proposed Regulations) under the new dividends received deduction (DRD) and anti-hybrid rules as enacted under Sections 245A and 267A, respectively.
Watch the replay of this webcast from Thursday 3 January 2019 where our panel of Tax Accounting Services (TAS) specialists take a deep dive into relevant tax accounting matters impacting year-end financial reporting.
The BEAT rules require certain corporations to pay a minimum tax on payments to non-US related parties. The Proposed Regulations, released on December 13, 2018, are the first regulatory guidance under new Section 59A, which was enacted by the 2017 tax reform act (the Act).
The US tax system is one of the most complicated in the world. It is important that individuals, organisations and employees understand the impact of US tax on everyday decisions.
The proposed regulations raise a number of important issues. PwC on December 12 hosted a webcast featuring PwC specialists who discussed some of these issues. This Tax Insight highlights those discussions and you can watch the webcast replay.
The proposed regulations raise a number of important issues. PwC on December 6 hosted a webcast featuring PwC specialists who discussed some of these issues. This Insight highlights those discussions.
The Proposed Regulations, are the first form of administrative guidance with respect to the foreign tax credit (FTC) regime following the enactment of the 2017 tax reform act (the Act).
On November 26, the US Treasury released proposed regulations (the Proposed Regulations) concerning the Section 163(j) interest expense limitation rules. We will discuss the Section 163(j) guidance in an upcoming Tax Reform Readiness series webcast.
Chairman Kevin Brady (R-TX) released a 297-page tax bill that includes a limited number of technical corrections to the 2017 tax reform act and more than 30 ‘tax extender’ provisions dealing with expired or expiring tax provisions.
On August 1, Treasury and the IRS released a 249-page set of proposed regulations under Section 965, addressing a wide range of issues regarding the toll charge. PwC on August 9 hosted a webcast featuring PwC specialists who discussed the proposed Section 965 regulations. This Insight highlights some of those discussions.
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.
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.
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.
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?
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.
The U.S. Tax Cuts and Jobs Act was signed into law on 22 December 2017 by President Donald Trump and significantly changed the taxation of non-U.S. corporations owned directly or indirectly by U.S. persons. This resource takes a closer look at who is impacted by the changes.
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.
The US Tax Cuts and Jobs Act which was signed into law on 22 December 2017 by President Donald Trump effectively doubled the existing lifetime Estate and Gift tax exclusion amount. Prior to the tax reform, an individual’s lifetime Estate and Gift tax exclusion was $5.49 million (2017 tax year), with the new exclusion amount from 1 January 2018 increasing to $11.2 million including inflation adjustment.
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 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.
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.
UK business with a US footprint will be impacted by the US tax reform, which includes a lower corporate tax rate and a broad range of cross border provisions.
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.
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.
