BDO News

This is a feed of the latest BDO USA Tax Publications.

International Tax Alert – October 2017

Applicability Date for Section 987 Regulations Extended by One Year Summary

In Notice 2017-57 (the “Notice”), the Department of the Treasury and the Internal Revenue Service (collectively, “Treasury), announced the intention to amend the regulations under IRC §987 to defer the applicability date of the final regulations under IRC §987, as well ... read more

International Tax Alert – October 2017

International Tax Proposals Included in the Tax Reform Framework Summary

On September 27, 2017, the White House and congressional Republicans released their tax reform framework, the Unified Framework for Fixing our Broken Tax Code (the “Framework”). The nine-page document outlines their objectives for tax reform, which they hope will stimulate the economy ... read more

Pending U.S. Tax Reform

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Moving from a worldwide system of taxation to a territorial system of taxation requires the ability to understand and build a framework for the future state. Given the emphasis placed by certain Congressional leaders and the White House on tax reform, U.S. multinational companies should be evaluating the ... read more

International Tax Alert – October 2017

Department of the Treasury Releases Report Recommending Changes to Eight Tax Regulations Summary

On October 2, 2017, the Secretary of the Department of Treasury (“Treasury”) issued a second report to President Trump on identifying and reducing tax regulatory burdens as directed by President Trump’s Executive Order 13789, a directive that instructed the Secretary ... read more

International Tax Alert – October 2017

U.S. District Court holds that an Anti-Inversion Regulation was Unlawfully Issued Summary

On September 29, 2017, the District Court for the Western District of Texas Austin Division granted the Plaintiff’s motion for summary judgment in Chamber of Commerce of the United States of America and Texas Association of Business v. Internal Revenue ... read more

Changing International Tax Landscape

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Finance executives of U.S. multinational organizations (“MNEs”) should review how the interplay of the following initiatives can impact them: (i) Pending U.S. tax reform’s international proposals; (ii) the OECD’s BEPS initiative; and (iii) Brexit.  

1. How does the interplay of these three initiatives impact:  Tax profile Treasury options Supply chain Corporate structure

 

2. What ... read more

R&D Tax Alert – October 2017

IRS Issues Guidance for Section 41 Research Credit Expenses for LB&I Taxpayers Summary

The IRS released a Directive dated September 11, 2017 (LB&I-04-0917-005), that provides guidance to Large Business & International (LB&I) Division examiners concerning Internal Revenue Code Section 41 credit for increasing research activities (Research Credit) examinations. The Research Credit is ... read more

Federal Tax Alert – September 2017

Tax Reform Framework Released

On Wednesday, September 27th , certain Congressional leaders of the Republican Party along with the White House released a framework for tax reform (the “Tax Reform Framework”).  The Tax Reform Framework proposes several individual, business, corporate and international tax changes to our existing tax system. Several of ... read more

International Tax Alert – September 2017

Proposed Regulations Provide Guidance on the Definitions of Registration-Required Obligation and Registered Form Summary

On September 19, 2017, the Department of the Treasury and the Internal Revenue Service (collectively, “Treasury”), published in the Federal Register proposed regulations (the “Proposed Regulations”) that provide guidance on the definitions of registration-required obligation and registered form, ... read more

International Tax Alert – September 2017

Treasury Issues Final Report with Recommendations to Repeal or Modify Certain Treasury Regulations

 

Summary

On [date], the Department of the Treasury released its final report (cite to document) recommending specific action to alleviate the burdens of eight regulations identified for review in Notice 2017-38. Notice 2017-38 was issued in response to President ... read more