20 October 2024 Americas Tax Roundup | 21 October 2024 | | A weekly summary of the top weekly tax news, trends and developments in the Americas | | | | | | | | | | This week's tax news from the Americas - United States | Final IRC Section 367(d) regulations open door to intangible property repatriation for US multinationals
On 9 October 2024, the United States Department of Treasury and the Internal Revenue Service released final regulations under IRC Section 367(d) (T.D. 9994; Final Regulations) on certain repatriations of intangible property (IP). The Final Regulations, which apply to IP repatriations occurring on or after October 10, 2024, are generally consistent with the proposed regulations published on May 3, 2023. The Final Regulations apply prospectively only, so taxpayers cannot rely on these rules for intangible property repatriations that occurred before their publication.
- Chilean Congress approves comprehensive tax compliance bill
The Chilean Chamber of Deputies passed a second comprehensive tax compliance bill. The legislation includes a modified application threshold for the general anti-avoidance rule, relationship rules for controlled foreign corporations, tax-haven regime requirements and a new anti-avoidance rule for value-added taxes. The bill is still undergoing the necessary legislative processes, including a constitutional review, and awaits formal promulgation and publication. The legislation will generally take effect the first day of the month following its publication, though provisions within the legislation may have varying effective dates.
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Document ID: 2024-1923 |