Thu, Nov 14, 2019
On October 7, 2019, the U.S. Department of the Treasury (Treasury) released its initial Priority Guidance Plan (PGP) for the year starting July 1, 2019 through June 30, 2020. The PGP (available here) puts forth guidance priorities for Treasury and for the Internal Revenue Service (IRS). Not surprisingly, the PGP puts highest priority on issuing additional regulatory guidance in association with the Tax Cuts and Jobs Act (TCJA).
The PGP includes several international tax and transfer pricing-related projects near the top of the list. Some of these projects have already been completed (such as the removal of Section 385 documentation requirement discussed elsewhere in this edition was announced on October 31) as of November 4, 2019.
Projects not yet completed include:
This plan may be subject to updating throughout the year as defined above. In any case, it is clear that Treasury and the IRS are giving a high priority to finalizing guidance on BEAT, FDII and GILTI. These provisions have been a significant area of focus for multinational taxpayers and for international tax and transfer pricing practitioners.
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