Canadian multinationals with U.S. operations may be affected by proposed new U.S. tax reform regulations.
Over the last few weeks, the IRS has issued proposed regulations related to provisions that were first included in the sweeping U.S. tax reform changes introduced in late 2017, including the Base Erosion and Anti-Abuse Tax (BEAT) provisions, the foreign tax credit, and interest expense changes. The proposed regulations include new details that Canadian multinationals should be aware of as they continue to make adjustments in light of the new U.S. tax reform changes.
In addition to these anticipated and broadly applicable proposals, the United States also recently released proposed regulations on:
The IRS is also expected to soon release guidance related to the treatment of hybrid instruments and entities and to the treatment of gains realized by non-U.S. taxpayers on the sale of US trade or business partnership interests. All these proposed regulations will be subject to a comment period before being finalized.
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