Submission to IRS and Treasury Concerning Notice 2018-43, 2018-2019 Priority Guidance Plan - International Tax Issues Including Profit Shifting

49 Pages Posted: 15 Aug 2018

See all articles by Jeffery M. Kadet

Jeffery M. Kadet

University of Washington - School of Law

David Koontz

Independent

Date Written: June 5, 2018

Abstract

This letter to the Treasury and the IRS is in response to Notice 2-43’s request for recommendations for the 2-2 Priority Guidance Plan on tax issues that should be addressed through regulations, revenue rulings, revenue procedures, notices, and other published administrative guidance. Many of the recommendations concern profit shifting by multinationals.

The letter provides extensive and specific suggestions for a number of international tax areas including:

-- Sourcing rules (§§863 and 864 in particular),

-- Entity classification rules (Reg §301.7701-1(a)(2)),

-- Subpart F manufacturing branch rule (Reg §1.954-3(b)), and

-- Application of tax treaties (Reg §1.894-1(d)).

Keywords: Profit Shifting, Notice 2-43, Sourcing Of Income, Subpart F, Entity Classification Rules, Check-The-Box, Manufacturing Branch Rule, Tax Treaties

JEL Classification: H21, H25, K34, E62

Suggested Citation

Kadet, Jeffery M. and Koontz, David, Submission to IRS and Treasury Concerning Notice 2018-43, 2018-2019 Priority Guidance Plan - International Tax Issues Including Profit Shifting (June 5, 2018). Available at SSRN: https://ssrn.com/abstract=3204852 or http://dx.doi.org/10.2139/ssrn.3204852

Jeffery M. Kadet (Contact Author)

University of Washington - School of Law ( email )

William H. Gates Hall
Box 353020
Seattle, WA 98105-3020
United States

David Koontz

Independent ( email )

Do you have a job opening that you would like to promote on SSRN?

Paper statistics

Downloads
39
Abstract Views
672
PlumX Metrics