1. US tax reform (00:39)
1.1 Corporate income tax rate, domestic dividends, and alternative minimum tax (AMT) (06:16)
1.2 Interest and net operating loss (NOL) deductions (02:38)
1.3 Full expensing of qualified property (05:58)
1.4 100% deduction for foreign dividends: "participation exemption" (06:58)
1.5 Deemed repatriation (09:08)
1.6 Intangible income: Global intangible low-taxed income (GILTI) (10:44)
1.7 Intangible income: Foreign-derived intangible income (FDII) (16:39)
1.8 Base erosion and anti-abuse tax (BEAT) (21:52)
1.9 Interest and royalties: outbound hybrid payments (26:13)
1.10 Alignment with BEPS Project (27:05)
1.11 Reading materials (29:27)
• To obtain a copy of the Tax Cuts and Jobs Act and conference report, as well as our Tax Alerts on this topic, visit www.deloitte.com/ap/dbriefs/bytescentral
2. OECD (29:54)
• For a copy of Second batch of stage 1 peer review reports regarding BEPS Action 14 minimum standards concerning MAP, and 4 "best practices" reports, and Online 2017 condensed version of OECD Model Treaty and Commentary, visit www.deloitte.com/ap/dbriefs/bytescentral
3. Asia Pacific (31:50)
• Australia, India, Japan, Malaysia
• For a copy of
– Australia’s guidance in regard to the diverted profits tax, and our Tax Alert on this topic
– Final version of Australia’s risk assessment approach for cross-border related party debt funding, and our Tax Alert on this topic
– India’s GST Council statement regarding implementation of a nationwide e-way bill system for inter-state movement of goods
– Our Tax Alert regarding Japan’s 2018 tax reform proposals
– Malaysia’s explanatory note in regard to recent changes concerning withholding tax on services performed outside of Malaysia
– Visit www.deloitte.com/ap/dbriefs/bytescentral
4. Europe (40:02)
• Denmark, ECJ, EU, Luxembourg, UK
• For a copy of
– Denmark's court decision in regard to Art. 5 (in Danish)
– European Court of Justice's decision in Avon Cosmetics case
– European Commission's announcement on its State Aid investigation in regard to two Netherlands private rulings given to a Dutch company within the IKEA group
– Luxembourg's guidance on certificate of tax residence for investment funds (in French) and our Tax Alert on this topic
– UK Upper Tribunal decision in English Holdings (BVI) Ltd case
– Visit www.deloitte.com/ap/dbriefs/bytescentral
5. Africa (47:03)
• Ghana, South Africa
• For a copy of South Africa’s new draft carbon tax bill and explanatory memorandum, visit www.deloitte.com/ap/dbriefs/bytescentral
6. Treaties (48:11)
• Croatia / Kosovo, France / Portugal, Qatar / Spain, Switzerland / UK, MLI : Jersey
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