Doug McHoney (PwC's US International Tax Services CoLeader) is live at the Westminster Studios with Sherry Grabow (PwC's US International Tax Services CoLeader) to discuss the international tax provisions in the recently released ‘Chairman’s Mark’ from the House Ways and Means Committee. Doug and Sherry cover, among other topics: Interest expense under new Section 163(n) and existing Section 163(j); changes to foreign derived intangible income (FDII), modifications to the global intangible lowtaxed income (GILTI) regime, changes to the foreign tax credit rules; sweeping changes to subpart F income; a refreshed base erosion and antiabuse tax (BEAT), and how taxpayers should prepare for potential changes to the tax rules.

Timestamps:

4:00 What are the changes to interest expense, specifically under new Section 163(n) which limits interest deduction of certain domestic corporations and foreign corporations that are engaged in a US trade or business and are members of an international financial reporting group?
8:30 What changes were made to the existing foreign derived intangible income provision?
12:30 What is the proposed new GILTI rate and overall changes to the calculation?
21:45 What are some of the changes to the foreign tax credit, induding the new carryforward and removal of the branch basket?
29:15 What are some of the surprising changes to the subpart F rules that have been around since 1962?
32:30 What are the proposed changes to BEAT?
36:00 What are some of the other international provisions contained in the House Ways & Means bill?
39:30 How should taxpayers prepare for these expected changes as we get closer to final legislation?