Tax Cuts And Jobs Act Impact Guide To International Tax Corporations

The CCH Answer Connect Guide on International Tax: Corporations is focused on the major changes made by the Tax Cuts and Jobs Act to the international tax rules that will affect most multinational corporations. These changes will likely require the alteration of global tax strategies and, particularly, the need to revisit and revamp transfer pricing arrangements. Although, the TCJA did not contain any significant modifications to the U.S. transfer pricing rules, the reduction of the U.S. corporate tax rate and the introduction of a base erosion and ant-iabuse tax, global intangible low-taxed income and foreign derived intangible income require that all U.S. taxpayers with cross-border activities, i.e., both inbound and outbound, develop different tax structuring and supply chain alternatives to develop an optimal tax strategy

The CCH Answer Connect Guide on Corporations explains the implications of the changes made by the Tax Cuts and Jobs Act. affecting C Corporations. Items in the Act that affect C Corporations include, among others, the new 21% corporate tax rate, the reduced corporate dividends deduction, the repeal of the corporate alternative minimum tax, new limits on business interest deductions, brief discussion of foreign tax provisions and choice of entity, the change to the maximum amount of taxable income that can be offset with NOL deductions, new asset expensing and depreciation tax breaks, the elimination of the Section 199 deduction, a new limitiation on deductions for excess business losses incurred by noncorporate taxpayers, elimination of the section 1031 rules that allow tax-deferred exchanges of appreciated like-kind property, and rules governing capitalization and amortization of specified R&D expenses.

This paper assesses the landmark Tax Cuts and Jobs Act (TCJA), from the perspective of both the U.S. itself and the wider world. The reform has many positive aspects including steps to broaden the base of, and reduce marginal rates under, the personal income tax (PIT), reduce distortions to investment and financing decisions, and mitigate outward profit shifting. But the TCJA has a large fiscal price tag and leaves significant uncertainty as to how the U.S. tax system will develop. The PIT changes could have better targeted relief at low earners, and there is scope to more fully address distortions in business taxation. The novel international provisions create a complex array of both positive and negative international spillovers, and have the potential to significantly reshape the wider international tax system.

The Tax Cuts and Jobs Act is considered the most sweeping tax law change in decades, and for many individuals and businesses the massive and complex changes will have profound impacts. The treatment of pass-through entities is one of the many areas where the new Act promises to fundamentally change the approach to tax planning for many business owners. The all-new CCH AnswerConnect: Tax Cuts and Jobs Act Impact - Guide to Pass-Through Entities is focused on the major changes made to the tax rules for pass-through entities, including limited liability companies (LLCs), partnerships, S Corporations and sole proprietorships. Currently, the income from these pass-through entities flows through to the individual owners and is taxed at the individual rate. However, the tax landscape for pass-through entities will change considerably under the new tax law.

The Tax Cuts and Jobs Act is considered the most sweeping tax law change in decades, and for many individuals and businesses the massive and complex changes will have profound impacts. The treatment of pass-through entities is one of the many areas where the new Act promises to fundamentally change the approach to tax planning for many business owners. The all-new CCH(R) AnswerConnect: Tax Cuts and Jobs Act Impact - Guide to Pass-Through Entities is focused on the major changes made to the tax rules for pass-through entities, including limited liability companies (LLCs), partnerships, S Corporations and sole proprietorships. Currently, the income from these pass-through entities flows through to the individual owners and is taxed at the individual rate. However, the tax landscape for pass-through entities will change considerably under the new tax law. The CCH Answer Connect Guide on Pass-Through Entites is focused on the major changes made by the Tax Cuts and Jobs Act in the way that business income generated by pass-through entities such as limited liability companies (LLCs), partnerships, S corporations or sole proprietorships is taxed. Under the old law, the net income of these pass-through entities was not taxed at the entity level but was taxed instead by the owners of the business at their individual tax rate. The Tax Cuts and Jobs Act adds a new section to the Code which provides that a non-corporate taxpayer who has qualified business income from a partnership. S corporation or sole proprietorship may be entitled to an additional deduction.

Whether your organization is contemplating a global move or is already involved in international business, you need to know about the activities that create multi-jurisdictional tax exposure and the required tax reporting for each relevant jurisdiction. Information is provided for Tax Reform and the impact of the Tax Cuts and Jobs Act of 2017, this guide covers international tax terminology and regulations that apply to a U.S. entity involved in global operations, or for a foreign entity doing business in the United States. Key topics include: Export income Receipts in foreign currency Allocation and apportionment of deductions U.S. foreign tax credit fundamentals and special rules Initiation of foreign operations Foreign branches and affiliated companies Sale of use of tangible property Foreign business operations in the United States Foreign business sales of tangible property in the United States Foreign business provision of services in the United States Exploitation of business assets outside of the United States Use of foreign tangible/intangible property in the United States U.S. withholding taxes on foreign businesses FDII GILTI

Discusses two fundamental principles of US taxation of international transactions, i.e. tax jurisdiction and the source of income rules. Explains how the US taxes the foreign activities of domestic corporations, US citizens and other US persons. Includes chapters on the foreign tax credit, the deemed paid foreign tax credit, transfer pricing, controlled foreign corporations, foreign sales corporations and income tax treaties. Describes how the US taxes the US activities of foreign corporations, non-resident alien individuals, and other foreign persons.

The 2017 Tax Cuts and Jobs Act (TCJA) sharply reduced effective corporate income tax rates on equity-financed US investment. This paper examines the reform’s impact on US inbound foreign direct investment (FDI) and investment in property, plant and equipment (PPE) by foreign-owned US companies. We first model effective marginal and average tax rates (EMTRs and EATRs) by country, industry, and method of finance, and then use those tax rates to calculate the tax semi-elasticities of inbound FDI and PPE investment. We find that both PPE investment and FDI financed with retained earnings responded positively to the TCJA reform, but FDI financed with new equity or debt did not. In country-level PPE regressions, inclusion of macroeconomic controls renders tax rate coefficients insignificant, suggesting that the increase in PPE investment after TCJA was driven by general economic growth. In regressions of FDI financed with retained earnings, however, tax coefficients were robust to inclusion of macroeconomic controls. As the literature predicts, EATRs have a greater impact on cross-border investment than EMTRs. Country-by-industry regressions showed a larger effect of taxes on PPE investment than aggregate country-level regressions, but industry-level tax rates appear to have no effect on earnings retention.