According to early versions of the 2018 U.S. budget that in November 2017 is making its way through the legislative process, a new 20% excise tax is to be introduced. The tax shall apply to almost all payments made by U.S. companies to non-U.S. affiliates of the same group (an “international financial reporting group”: subsidiaries, parents companies, and sister companies). The tax will not be deductible from U.S. corporate