The US Treasury Department and the Internal Revenue Service (IRS) have issued final regulations concerning the global intangible low-taxed income (GILTI) regime under Section 951A, as well as final and proposed regulations concerning foreign tax credits, domestic partnerships, subpart F income, and the treatment of certain controlled foreign corporation (CFC) income.
According to the IRS, the final GILTI regulations provide guidance to determine the amount of global intangible low-taxed income included in the gross income of certain US shareholders of foreign corporations, including US shareholders who are members of a consolidated group.
The final GILTI regulations retain, with certain modifications, the anti-abuse provisions that were included in the proposed regulations and revise the domestic partnership provisions to adopt an aggregate approach for purposes of determining the amount of global intangible low-taxed income included in the gross income of a partnership’s partners under Section … Read More »
In early June, the European Union recommended that Ireland broaden its tax base and take further steps to crack down on aggressive tax planning. The EU said that Ireland’s public finances have improved, but suggested that the risks of revenue volatility remain and that the revenue base could be made more resilient. According to the EU, “limiting the scope and number of tax expenditures and broadening the tax base would improve revenue stability in the face of economic volatility.” The Union recommended that Ireland should “continue to address features of the tax system that may facilitate aggressive tax planning, and focus in particular on outbound payments.”
Then, hot on the heels of the EU grumblings, not for the first time, the Irish Fiscal Advisory Council warned the Government about funding spending increases or tax relief with high corporate tax receipts. According … Read More »
Barbados recently announcing sweeping changes to its personal income tax and VAT regimes. Effective July 1, 2019, Barbados will remove the 16 percent lowest income tax rate and the second rate of 33.5 percent. Instead, the lowest tax rate on income up to BSD50,000 will be 12.5 percent. The rate on income above this threshold will fall from 40 percent to 33.5 percent, between July 1, 2019, and December 31, 2019, and from January 1, 2020, the rate will fall to 28.5 percent.
However, while this sounds, on the surface of it, to be good news for Barbadians, from May 1, a new obligation has been introduced for foreign suppliers to charge VAT on supplies to consumers in the jurisdiction, in addition to the introduction of a 20 percent withholding tax on gambling winnings from lotteries and betting, new limits on … Read More »