There has been an overhaul in the international tax rules for businesses as a result of the Tax Cuts and Jobs Act of 2017. Treasury and the IRS have issued regulations and other guidance on the application of these new rules. As a result, companies must consider these changes in the international tax system when structuring transactions or entering into joint venture arrangements. We will explore some of these new developments and how they may impact certain transactions and structures, providing real life examples of the application of these rules.
Understand international tax planning framework and highlight key traps for businesses.