Tax technical updates: PwC's Law Firm Services News Alerts

Update on the introduction of VAT in the Middle East

As addressed in PwC’s Law Firm News Alert distributed on April 19, 2017, the members states of the Gulf Cooperation Council (GCC) – comprised of the monarchies in Bahrain, Kuwait, Oman, Qatar, Saudi Arabia, and the United Arab Emirates (UAE) – are expected to adopt an 'EU-style' VAT model, whereby each member state adopts national legislation within a set framework. Implementation of VAT is expected to begin as of January 1, 2018.

IRS re-releases proposed regulations t0 implement new partnership audit rules

On June 13 the IRS re-released proposed regulations (REG-136118-15, the Proposed Regulations) to implement the centralized partnership audit regime enacted as part of the Bipartisan Budget Act of 2015 (the BBA rules). The newly released version of the Proposed Regulations is essentially the same as the version that was unofficially released in January 2017 and then withdrawn in response to an executive order issued by the incoming Administration. It is significant that the IRS has now officially released the Proposed Regulations, set a deadline (August 14, 2017) for receipt of written comments, and scheduled a hearing on the proposed rules for September 18, 2017.

Update on CRA’s Proposed Treatment of Limited Liability Partnership (LLP) Formed Under the Laws of Delaware and Florida

On July 5, 2016, PwC issued a News Alert on the changes announced by the Canada Revenue Agency (“CRA”) at the May 2016 International Fiscal Association Conference (Canada branch) held in Montreal regarding the treatment of both limited liability limited partnerships (LLLP) and limited liability partnerships (LLP) formed under the laws of Delaware or Florida as corporations for Canadian tax purposes (subject to some transition rules). Click here to view the News Alert.

Trump Administration officials announce tax reform principles

Treasury Secretary Steven Mnuchin and White House National Economic Council (NEC) Director Gary Cohn unveiled last week the Trump Administration’s principles (the Principles) for tax reform that call for lowering business tax rates to 15 percent which will apply to both corporate and non-corporate entities. However there was no detail shared how this business tax rate will specifically apply to pass-through entities or if distributions will be taxed as well. Issued as a one-page document, the Principles also call for moving the US to a territorial tax system from the current worldwide tax system, and for enacting a one-time repatriation tax on the foreign earnings of US companies. Secretary Mnuchin stated that the specific rate for a repatriation tax would be the subject of negotiations with Congress. (PwC)

Contact us

Gary Pogharian
Tax Partner
Tel: +1 (646) 471 7202
Email

Gregg Sincoff
Tax Managing Director
Tel: +1 (646) 471 1335
Email

Nancy Regan
Tax Director
Tel: +1 (973) 236 5771
Email

Follow us