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12 February 2018

US IRS updates Priority Guidance Plan to add projects implementing some TCJA international provisions

The United States (US) Internal Revenue Service (IRS) has issued the second quarter update to its 2017-18 Priority Guidance Plan, adding new guidance projects to implement the changes enacted by the Tax Cuts and Jobs Act (TCJA). This Alert highlights additions related to international provisions.

Background

The IRS issued the initial 2017-18 Priority Guidance Plan in October 2017. The plan gives an overview of the projects that the IRS intends to address in the plan year ending 30 June 2018. As in prior years, the IRS updates the plan periodically to reflect additional guidance that it intends to publish.1

On 22 December 2017, the President signed into law the TCJA, overhauling the Internal Revenue Code2 and enacting a number of new and revised international tax provisions.3

New international projects

The second quarter update to the 2017-18 Priority Guidance Plan includes 18 new projects related to the implementation of the TCJA. The introduction to the plan update describes these projects as "near term priorities." The plan update also adds several other new projects relating to guidance that the IRS has issued over the past several months. Several of the TCJA implementation projects relate to international provisions, including:

  1. Computational, definitional and other guidance under new Section 163(j)
  2. Guidance implementing new Section 965 and other international sections of the TCJA (this guidance was published as Notice 2018-07)4
  3. Guidance under new Section 1446(f) for dispositions of certain partnership interests (this guidance was published as Notice 2018-08)5

Implications

Taxpayers that are interpreting new Section 163(j), new Section 965, new Section 1446(f) and other international sections of the TCJA should continue to monitor the release of new guidance, and should consult with tax advisors as new guidance is issued.

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ENDNOTES

1.  For a detailed discussion of the international projects included in the 2017-18 initial plan, see EY Global Tax Alert, US Treasury and IRS 2017-2018 Priority Guidance Plan shifts focus to reducing burdens and complexity, dated 31 October 2017.

2.  All "Section" references are to the Internal Revenue Code of 1986, and the regulations promulgated thereunder.

3.  For a detailed discussion of the TCJA international provisions (including those highlighted under New international projects), see EY Global Tax Alert, US House and Senate release the Conference Report on the Tax Cuts and Jobs Act, dated 21 December 2017.

4.  See EY Global Tax Alert, US IRS issues guidance on transition tax on foreign earnings, dated 2 January 2018.

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CONTACTS

For additional information with respect to this Alert, please contact the following:

Ernst & Young LLP, US International Tax Services

  • Joshua Ruland, Washington DC
    joshua.ruland@ey.com
  • Joe Ryan, Chicago
    joe.ryan@ey.com

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ATTACHMENT

PDF version of this Tax Alert

Document ID: 2018-5274

 
 

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