International Tax Year-End Planning Considerations

This guide outlines key considerations for year-end international tax planning in light of recent legislative changes and ongoing compliance requirements. It discusses the implications of the Tax Cuts and Jobs Act of 2017 and the Pillar Two initiative, emphasizing the need for taxpayers to prepare for potential increases in their global effective tax rate and tighter reporting standards. The document details specific areas such as Partnership K-2 and K-3 reporting, foreign-derived intangible income (FDII) planning, and global intangible low-taxed income (GILTI) planning. Additionally, it addresses the base erosion and anti-abuse tax (BEAT) and foreign tax credit planning, highlighting the importance of understanding eligibility and limitations. The guide also emphasizes the necessity for U.S. taxpayers to comply with country-by-country reporting requirements and consider transfer pricing issues. Overall, it serves as a comprehensive resource for taxpayers navigating the complexities of international tax obligations and strategies for effective planning.