Global Trade Alert
Global Trade Alert

United States of America: Provisions in the Tax Cuts and Jobs Act affecting international transactions

Announcement

20 Dec 2017

In December, 2017 the United States made a major overhaul in its tax law, with some provisions affecting the taxation of international transactions. The main thrust of the bill is to reduce the rates at which individuals and businesses are taxed and to simplify the rules of the tax system. One of the additional objectives of the bill’s authors and negotiators was to encourage the repatriation to the United States of profits currently held in foreign countries by U.S. multinational corporations. Or as described by the authors, the bill “[m]odernizes our international tax system so America’s global businesses will no longer be held back by an outdated ‘worldwide’ tax system that results in double taxation for many of our nation’s job creators” and “[p]revents American jobs, headquarters, and research from moving overseas by eliminating incentives that now reward companies for shifting jobs, profits, and manufacturing plants abroad.”

 

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Number of interventions

2

1 certainly harmful

0 likely harmful

1 liberalising

List of interventions

Implementation date

01 Jan 2018

Revocation date:

No revocation date

Updated: 20 Dec 2017
Tax-based export incentive In force

Section 14201 of the 2017 Tax act establishes a new permanent corporate income tax deduction for a subset of overseas earnings. The deduction for "Foreign-Derived Intangible Income" (FDII) provides...

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Implementation date

01 Jan 2018

Revocation date:

No revocation date

Updated: 20 Dec 2017
Local content incentive In force

Section 13305 repeals the deduction for income attributable to domestic production activities. Existing law (Section 199 of the tax code) provides a deduction from taxable income (or, in the case o...

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