Section 385 debt/equity regulations proposed for Labor Day issuance, noting there is alot of uncertainty until then based on the Proposed Regulations, including the impact on physical and/or notional cash pools.
US House tax reform blueprint to be released this month.
Country-by-country (CbC) voluntary reporting is being acknowledged as a gap and problematic for US based MNE’s, thus one US CbC global report is not anticipated to be the result, requiring multiple CbC reporting required by relevant countries. For countries that have agreed to accept voluntary filing, it would be beneficial to provide a simple public chart by the administration for taxpayer access.
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