US developments dominate the headlines in this month’s update by Tim Sarson (KPMG).
US budget reconciliation: the One Big Beautiful Bill Act
On 22 May 2025 the House of Representatives passed its budget reconciliation Bill (the ‘One Big Beautiful Bill Act’) that would generally make permanent the expiring provision of the 2017 Tax Cuts and Jobs Act (TCJA). Notable although not exhaustive observations on the international tax provisions of the Bill include:
Extensions of current law
The legislation sets permanent rates for the Global Intangible Low-Taxed Income ‘GILTI’ of 10.668% (currently 10.5%) Foreign-Derived Intangible Income ‘FDII’ of 13.335% (currently 13.125%) and Base Erosion and Anti-abuse Tax ‘BEAT’ of 10.1% (currently 10%).
Notably the legislation does not extend the Controlled Foreign Company (CFC) look-through rule of IRC...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
US developments dominate the headlines in this month’s update by Tim Sarson (KPMG).
US budget reconciliation: the One Big Beautiful Bill Act
On 22 May 2025 the House of Representatives passed its budget reconciliation Bill (the ‘One Big Beautiful Bill Act’) that would generally make permanent the expiring provision of the 2017 Tax Cuts and Jobs Act (TCJA). Notable although not exhaustive observations on the international tax provisions of the Bill include:
Extensions of current law
The legislation sets permanent rates for the Global Intangible Low-Taxed Income ‘GILTI’ of 10.668% (currently 10.5%) Foreign-Derived Intangible Income ‘FDII’ of 13.335% (currently 13.125%) and Base Erosion and Anti-abuse Tax ‘BEAT’ of 10.1% (currently 10%).
Notably the legislation does not extend the Controlled Foreign Company (CFC) look-through rule of IRC...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
