The US Senate Finance Committee has this week voted 23 to 3 to approve legislation extending more than 50 expired tax breaks, including some of keen interest to large, cross-border businesses such as the research and experimentation tax credit, the subpart F active financing exception, 50% bonus depreciation for qualifying properties, and the look-through treatment of payments between related controlled foreign companies.
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The new guidance is not meant to reflect a substantial change to UK law, but the requirement that tax advice is ‘likely to be correct’ imposes unrealistic expectations
China and a clutch of EU nations have voiced dissent after Estonia shot down the US side-by-side deal; in other news, HMRC has awarded companies contracts to help close the tax gap