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Proposed Regulations Would Conform Subpart F High-Tax Exception to GILTI High-Tax Exception

On July 20, 2020, the US Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued proposed regulations (REG-127732-19) (the 2020 Proposed Regulations) that would conform the historic Subpart F...more

Eligibility Requirements for Reduced Tax Rate on FDII for Royalties

A domestic corporation's royalty income derived in connection with business conducted outside the United States generally is eligible for the reduced 13.125 percent effective tax rate on foreign derived intangible income...more

The New Deduction for Foreign-Derived Intangible Income

The 2017 tax reform legislation added section 250 to the Internal Revenue Code, effectively creating a new preferential tax rate for income derived by domestic corporations from serving foreign markets. The new deduction is...more

Senate Passes Bill Including Comprehensive Business Tax Reform Measures

The Senate has passed its version of the Tax Cuts and Jobs Act, which includes substantial changes to the corporate and international business taxation rules. Senate passage was probably the most significant political and...more

Is a Business Tax Reform Game Plan Beginning to Take Shape?

Substantial tax reform is underway and the business community is intently awaiting details of this activity with the aim of positioning themselves to maximize opportunities and minimize any costs or risks that reform may...more

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