Stay informed and prepared for the changes to the US taxation system
The Trump administration's plan for comprehensive tax reform is a concern for Canadian companies that are invested in the United States. Companies with activities in the United States will need to stay informed and prepared for this impending overhaul of the US taxation system.
PwC Canada was engaged by the Business Council of Canada to estimate the impact of the United States Tax Cuts and Jobs (“US tax reform” or the “Act”) on the Canadian economy.
The regulations seek to limit the benefits of section 245A where “the literal effect of section 245A would reverse the intended effect of the subpart F and GILTI regimes.”
The Final Regulations and Proposed Regulations provide guidance relating to a US shareholder's pro rata share of its global intangible low-tax income (GILTI).
Final and new proposed GILTI regulations, and temporary DRD regulations under Section 245A were released by Treasury
Treasury released proposed regulations (the Proposed Regulations) under new Section 250 on March 4.
The regulations contain 85 pages of preamble language and 82 of regulatory text, including 38 examples.
The Section 199A final regulations raise a number of important issues; this Insight highlights those issues.
Final regulations are released providing guidance on the Section 199A passthrough deduction.
The IRS on January 15 released final regulations under Section 965 that retain the overall structure and basic approach of the proposed regulations.