U.S. Inbound Corner
U.S. Inbound Corner is a bulletin of the latest tax developments affecting businesses investing into the United States. Written by professionals of the Deloitte member firms, the newsletter provides invaluable insights on a broad range of topics affecting US inbound taxpayers.
Impact of the Proposed 385 Regulations on Cash-Pooling Arrangements: On April 4, 2016, the US Department of Treasury and the Internal Revenue Service issued proposed regulations under section 385. This article highlights certain provisions contained in the Proposed 385 Regulations related to cash-pooling arrangements, certain negative impacts, recommendations for mitigation made by commenters, and the current legislative outlook as it relates to cash-pooling arrangements.
Proposed debt-equity regulations: Unintended state tax headache?: The article discusses several state tax issues raised by the proposed Treasury regulations under IRC section 385, including state conformity, the potential state tax issues that may arise for states with filing groups that differ from the federal affiliated group, and the potential issues for documentation of intercompany debt transactions for state tax purposes.
Tax Data Analytics and Country-by-Country Reporting: Insight to Action: Over the last two years, the Organization for Economic Co-operation and Development (OECD) has been working on its Base Erosion and Profit Shifting (BEPS) project, “the first substantial renovation of the international tax rules in almost a century.” One of the key BEPS changes is the introduction of Country-by-Country Reporting (CbCR) requirements for multinational corporations (MNCs) with turnover in excess of €750 million. CbCR will give tax authorities access to detailed financial information about group operations worldwide.
Calendars to watch: Each edition, be sure to mark your calendars for some of the more important events (recent and upcoming) as well as tax developments making in impact on businesses investing into the United States.