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KPMG LLP (KPMG) is pleased to invite you to a TaxWatch Webcast that will discuss how new law (tax reform and proposed regulations) may affect treasury functions.
The president signed into law H.R. 1, originally known as the “Tax Cuts and Jobs Act,” in late December 2017. A number of provisions in the new law directly affect treasury’s functions, which will be discussed on this Webcast, including:
- New tax on global intangible low-taxed income (GILTI) under section 951A
- Revisions to section 163(j) that limit interest expense deductibility
- New anti-base erosion (section 59A) and anti-hybrid (section 267A) rules that can further eliminate tax benefits from routine treasury payments to related parties.
In addition to tax reform, the Treasury and the IRS issued proposed regulations affecting currency transactions in December 2017, including proposed regulations that, if enacted, could:
- Expand the application of the business needs exception under section 954
- Permit taxpayers to mark-to-market section 988 transactions, including the taxpayer’s own debt liabilities.
Professionals from KPMG’s Washington National Tax (WNT) practice and KPMG’s Treasury Advisory practice will discuss the new law and leading practices for treasury groups, including whether the United States may now be considered an attractive jurisdiction in which to form a treasury center.