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.
Final US regulations provide guidance on the Section 199A passthrough deduction
The IRS and Treasury have released final regulations under Sections 199A and 643.
Webcast: Issues under the Section 199A final regulations
Join us on Tuesday, February 12, 2019 from 2-3:00PM ET for the latest webcast in our Tax Readiness series.
IRS issues Q&As on Section 965 transition tax issues for 2018 returns
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.
Deadline extended for avoiding acceleration toll tax instalment payments
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.
Highlights of the final ‘toll tax’ regulations under Section 965
The final regulations provide guidance relating to the "toll tax" due upon the mandatory deemed repatriation of certain deferred foreign earnings.
Webcast: Finally final. The section 965 regulations
Replay of the latest webcast in our Tax reform readiness series: Finally final. The section 965 regulations.
Top policy trends and an outlook for 2019
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.
Moving beyond tax reform: 2019 US tax policy outlook
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.
Your new year's resolution - learn about the Sections 245A and 267A regulations.
Watch the replay from this latest webcast in our Tax reform readiness series.
State tax implications: 2018 federal tax reform guidance
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 releases proposed anti-hybrid regulations
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.
Webcast: Q4 financial reporting considerations
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.
Webcast: We got the BEAT (proposed regulations)
Watch the replay from this webcast held on Wednesday, December 19, 2018.
Treasury releases proposed BEAT regulations
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).
2018 Year End Considerations
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 FTC regulations — Credit given (maybe) where credit is due
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.
Practical reaction to the Section 163(j) regulations
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.
US Treasury releases proposed foreign tax credit regulations
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).
Treasury releases proposed Section 163(j) regulations
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.
House Ways and Means Chairman Brady proposes year-end bill on tax technical corrections, extenders, and other issues
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.
Webcast: Year end state tax considerations
Watch the replay from this webcast held on Wednesday, December 5th.
Tax Function of the Future webcast: Legal entity strategy and simplification post-tax reform
View the recording of this webcast held on November 13, 2018.
Webcast: Threading tax reform through the EU mandatory disclosure and OECD multilateral instrument needles
Watch the replay from this latest webcast held on Wednesday, October 31st.
Special edition webcast: Opportunity zones proposed regulations - Optimizing benefits and avoiding pitfalls
Watch the replay from this webcast held on Tuesday, October 30th.
Webcast: So you (still) haven't digested the proposed 951A regs? Don't feel GILTI
Watch the replay from our latest webcast held on Wednesday, October 24th.
Webex: Deeper dive on bonus depreciation
Watch the replay from this webcast held on Wednesday, 17 October.
Webcast: Initial guidance on new limits on executive compensation deductions
Watch the replay of this webcast held on Wednesday, September 26, 2018 .
Webcast: Overview of the GILTI regulations
Watch the replay of this webcast held on Wednesday, September 19, 2018.
The proposed ‘toll charge’ regulations
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.
Special edition webcast: Understanding IRS Guidance on Section 199A Implementation
Replay from this special edition webcast in our Tax reform readiness series held on Thursday, August 30, 2018.
Webcast: Do the depreciation regulations provide a bonus?
Replay from this webcast in our Tax reform readiness series held on Wednesday, August 29, 2018.
Webcast: The politics of implementation
Replay from the latest webcast in our Tax reform readiness series. held on Wednesday, August 22, 2018.
Treasury and the IRS release proposed Section 965 regulations
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.
Webcast: Mobile workforce in the age of tax reform
Watch the latest webcast in our Tax reform readiness series, held on Wednesday, August 15, 2018.
Special edition webcast: An update on 965 regs
Replay of a special edition webcast in our Tax reform readiness series held on Thursday, August 9, 2018.
Webcast: BEAT mechanics and selected issues
Watch the replay from this latest webcast in our Tax reform readiness series held on 1 August 2018.
Webcast: Implications for US tax treaties
Watch this webcast from the latest in our Tax reform readiness series, held on Wednesday, 8 August 2018.
Webcast: State tax compliance considerations
Watch this webcast replay from 25 July, 2018 for the latest in our Tax reform readiness series.
Webcast: Partnership monetization vehicles post tax reform
Watch the replay from the latest webcast in our Tax reform readiness series.
Webcast: Transforming your transfer pricing strategy in the new world order
Watch the replay from the latest webcast in our Tax reform readiness series.
Webcast: Six months in...looking back and looking ahead
Watch the replay of the latest in our tax reform readiness webcast series.
Webcast: Global reaction to US reform
Watch the replay from the latest webcast in our Tax reform readiness series.
Webcast: Thinking outside the tax box — macroeconomic and geopolitical impacts
View the latest webcast in our Tax reform readiness series.
Webcast: GILTI mechanics and selected issues
Watch the replay from the latest webcast in our Tax reform readiness series.
Webcast - A global company perspective
Watch the replay from the latest in our tax reform readiness webcast series.
Webcast: Business decision-making in the post tax reform world: Early observations
Watch the replay of the latest in our tax reform readiness webcast series.
Webcast - Today's emerging technologies for tax reform readiness
Watch the latest in our tax reform readiness webcast series for a look at the impact emerging technologies are having on the tax function.
Why Tax Reform Changes Nothing — and Everything
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?
Interactions of international tax reform provisions
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.
Webcast - Impact on deals and JV alliances
Watch the latest in our tax reform readiness webcast series.
Webcast - Interaction of international provisions
Watch the latest in our tax reform readiness webcast series.
Webcast: Interim financial reporting
Watch this webcast in PwC’s Tax reform readiness series.
Webcast: Are you capitalising on your fixed asset opportunities?
Watch the replay of this webcast from our tax reform readiness series.
US Treasury and IRS release third notice on toll tax
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.’
US tax reform – Implications for US family members in a Canadian business
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.
Webcast - What should treasurers do today?
Watch this webcast replay from 4 April 2018 for the latest in our tax reform readiness webcast series.
Impacts on treasury
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.
Talking Tax Podcast: US Tax Reform - Why is it a big deal?
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?
Webcast: Repatriating previously taxed income / Accessing foreign cash
Watch this webcast replay from Wednesday 7 March 2018 for the latest in our tax reform readiness webcast series.
Potential valuation opportunities
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: Understanding the impact on human capital investments and mobility
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 impact on operating models
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.
A closer look at TCJA 2017
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.
US tax reform webcasts - recordings now available
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.
US Estate Tax reform
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.
The impact on individuals
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.
Bill signed into law
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.
Impact for employee benefits programmes
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.
Accounting considerations
Find out how sweeping changes to the US tax law will impact your company's financial statements.
Congress gives final approval to tax reform conference committee agreement
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.
Frequently asked questions: Accounting considerations of US tax reform
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.
Conference committee reaches agreement on final bill
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.
What's happening with tax reform? An update for global businesses in the USA
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.
US Year-end considerations & tax reform
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.
Understanding the impact of US tax reform on financial reporting
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.
Audit considerations
PwC partners Len Combs and Jennifer Spang discuss the audit considerations associated with US tax reform proposals.
Impact on US international tax rules
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.