International Tax ADVISORY – Trump’s Tax Reform Plan When the Dessert Pays for Dinner

President Trump is beginning to follow through on Candidate Trump’s promises to overhaul the tax code. Our International Tax Group examines the few details we have and the path any legislation must take to become law.

Unsurprisingly, the IRS got the same result by trying the same thing. Our International Tax Group analyzes the agency's latest effort to use a discounted cash flow analysis to audit a cost-sharing agreement. The difference between #255 million and $3.6 billion Using the comparable uncontrolled transaction method Applying the 2011 cost-sharing regulations Read the full advisory by clicking here. [...]Read more

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Ultimate parents of U.S. multinational enterprises now have instructions for Form 8975, the U.S. Country-by-Country Report. Our International Tax Group reviews what U.S. MNEs must do to comply with new U.S. filings requirements, as well as procedures for voluntary early filing intended to satisfy BEPS-related Organisation for Economic Co-operation and Development guidance in other jurisdictions. Fixing the reporting mismatch Revenue Procedure 2017-23 The form and instructions Read the full International Tax Advisory here. [...]Read more

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This week, the House will vote on a budget resolution that combines the Trump Administration’s tax and other legislative initiatives into a single package. Should that fail to clear the lower chamber’s narrow GOP majority, Senate Republicans are moving forward with a “Plan B” proposal, which would separate the tax legislation into a second bill to be considered later in the year. 

This week, the Senate week will begin confirmation hearings for a slew of Trump Administration cabinet nominees. The upper chamber will also take up legislation requiring the detention of people who are in the United States illegally and are arrested for, or charged with, theft. House, Republicans, who hold a razor-thin majority, continue to debate the strategy of pushing through President-elect Trump’s legislative priorities in a single reconciliation bill.