Panelist: | Dianne C. Mehany |
Program: | International Tax Reform |
Event Sponsor: | American Bar Association Section of Taxation 2018 Midyear Meeting |
Where: | Hilton Bayfront San Diego
1 Park Boulevard
San Diego, CA 92101-7897
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Registration: | Click Here To Register |
The landscape of international tax under U.S. law has changed drastically with meaningful consequences to taxpayers. For instance, newly passed changes in tax law champion unique and robust provisions to effectively tackle base erosion and tax abuse. Additionally, taxpayers will face new limitations on deductions of business interest expense, with domestic corporate members of worldwide groups facing additional limitations on deductible interest expense generally. The new law not only changes the landscape of international tax under domestic law, but some of these provisions potentially cause treaty override issues that run the risk of unilaterally altering current bilateral tax treaty obligations and negatively effecting relationships with treaty partners. This panel will provide an overview of the newly passed tax reform provisions and discuss some of the unique issues the changed laws bring to international tax practice