United States

Amanda Varma and Brigid Kelly of Steptoe & Johnson LLP, Washington, discuss the international tax provisions in the Tax Cuts and Jobs Act of 2017, including the new dividend-exemption system, the GILTI and FDII provsions, and the BEAT . . .

The US IRS on December 29 released an advance version of Notice 2018-07, providing guidance on how multinationals should compute the taxes arising from a deemed repatriation of their foreign earnings accumulated offshore, called for under the US’s newly . . .

Amanda Varma and Brigid Kelly of Steptoe & Johnson, Washington, discuss the implications of the US district court’s decision Starr International Co. Inc. v. US, issued August 14, where the court concluded that the US competent authority acted reasonably when it denied a taxpayer’s request for discretionary tax treaty benefits under the US-Switzerland tax treaty. . . 

Monte A. Jackel, Senior Council at Akin, Gump, Strauss, Hauer & Feld, writes about the need for US tax guidance addressing situations where the stock of a controlled foreign corporation (CFC) is held by a foreign partnership whose partners consist of US persons . . . 

US Treasury’s plan to revise six problematic areas in the proposed section 385 debt-equity regulations does not go far enough to allay concerns about regs’ negative impact on the US economy, Republican lawmakers . . .