Final Copy of Tax Reform Bill Released: The enrolled reconciliation bill as passed by the House and Senate, H.R. 1, has been released.
Additional Automatic Exchange Relationships Activated in Accordance With BEPS Action 13: Today, in accordance with the BEPS Action 13 minimum standard, additional automatic exchange relationships were activated under the Multilateral Competent Authority Agreement on the Exchange of Country-by-Country (CbC) Reports. The automatic exchange of CbC reports, set to start in June 2018, will give tax administrations around the world access to key information on the annual income and profits, as well as the capital, employees, and activities of multinational groups that are active within their jurisdictions. The full list of the more than 1,400 automatic exchange relationships can be found here.
Revenue Ruling 2018-03 clarifies that a package of films licensed to a customer (for example, a television channel) that is disposed of by a taxpayer in the normal course of business as one property may be an item under Treas. Reg. § 1.199-3(d)(1)(i) for determining the domestic production activities deduction under section 199.
Notice 2018-05 permits qualifying withholding agents to apply the transition rules in Notice 2010-46 for calendar years 2018 and 2019.