On December 19, 2023, the recently ratified Convention Between the Government of the United States of America and the Government of the Republic of Chile for the Avoidance of Double Taxation and the Prevention of Fiscal...more
On December 15, 2023, the Internal Revenue Service (IRS) and Department of the Treasury (Treasury) released Notice 2024-10 (Notice) addressing the potential double counting of income from controlled foreign corporations...more
The Internal Revenue Service (IRS) and US Treasury Department (Treasury) issued Notice 2023-80 (Notice) on December 11, 2023, addressing the extension of relief previously announced under the foreign tax credit rules, and...more
The Supreme Court granted certiorari on June 26 with respect to the Ninth Circuit’s decision in Moore v. United States. The question presented is whether the section 965 transition tax is a “direct tax” that violates the...more
On June 7, 2023, the IRS released Notice 2023-42 (the Notice), providing taxpayers relief from the addition to tax under Section 6655 in connection with the application of the new corporate alternative minimum tax (CAMT). In...more
On March 28, 2022, the Biden Administration released the 2023 Fiscal Year Budget (the Budget) followed by the release of the Treasury’s Green Book, which provides explanations of the Biden Administration’s revenue proposals....more
On March 28, 2022, the Biden Administration released the 2023 Fiscal Year Budget (the 2023 Budget). It is important to note that the Budget assumes the Build Back Better Act (the BBBA) will be enacted as passed by the House...more
The IRS recently released a trio of Revenue Procedures - 2021-48, 2021-49, and 2021-50 - related to the Paycheck Protection Program (PPP), which has been the subject of a number of our previous legal alerts. Some alerts can...more
On August 25, 2021, Senate Finance Committee members Wyden, Brown, and Warner released draft bill language and a section-by-section summary of their proposed International Tax Reform Framework. The legislative language is...more
9/1/2021
/ Base Erosion and Anti-Abuse Tax (BEAT) ,
Corporate Taxes ,
Foreign Derived Intangible Income (FDII) ,
Foreign Profits ,
GILTI tax ,
Green Book ,
International Tax Issues ,
OECD ,
Proposed Legislation ,
Tax Cuts and Jobs Act ,
Tax Rates ,
Tax Reform
As Congress and the White House look to make a deal on infrastructure by this summer, negotiations regarding changes in the tax law continue. Since our prior alert, while progress has been made regarding a bipartisan...more
7/8/2021
/ Biden Administration ,
Budget Reconciliation ,
Congressional Committees ,
Corporate Taxes ,
Foreign Derived Intangible Income (FDII) ,
GILTI tax ,
International Tax Issues ,
OECD ,
Proposed Legislation ,
Reconciliation ,
Tax Cuts and Jobs Act ,
Tax Rates ,
Tax Reform
Just a few months after regulations were finalized, and as taxpayers were getting comfortable with the international tax provisions implemented by the 2017 Tax Cuts and Jobs Act (TCJA), proposals from President Biden and the...more
Recently released final regulations provide some relief to taxpayers that are subject to high foreign taxes on their global intangible low-taxed income (GILTI), but whether the GILTI high-tax exclusion is beneficial to any...more
Significant provisions of the 2020 Proposed Regulations addressing the application of section 163(j) to foreign corporations and their shareholders include:
..An election under which a controlled foreign corporation (CFC)...more
As COVID-19 continues to spread around the globe, companies and individuals are facing a diverse and challenging set of issues. These issues span a number of different contexts including tax, and measures are being considered...more
A year after the initial proposed BEAT regulations were released, Treasury and the IRS have issued a package of final and proposed regulations under § 59A of the Internal Revenue Code of 1986, as amended (the Code), the...more
On 9 October 2019, the Organisation for Economic Co-Operation and Development (OECD) published its latest public consultation paper in relation to its proposals to address the challenges of taxing the digital economy,...more
On May 23, 2019, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued final regulations (TD 9859) (the Final Regulations) modifying the application of section 956 of the Internal Revenue...more
5/31/2019
/ Congressional Review Act ,
Controlled Foreign Corporations ,
Corporate Taxes ,
Dividends ,
Internal Revenue Code (IRC) ,
IRS ,
Partnerships ,
Section 956 ,
Shareholders ,
Tax Cuts and Jobs Act ,
U.S. Treasury
On April 16, 2019, the Large Business and International (LB&I) Division of the Internal Revenue Service (IRS) announced three new compliance campaigns. The campaigns focus on:
..Transfer pricing for “captive” services...more
4/29/2019
/ Controlled Foreign Corporations ,
Corporate Taxes ,
FATCA ,
Filing Requirements ,
Internal Revenue Code (IRC) ,
IRS ,
Large Business & International Division (LB&I) ,
OECD ,
Offshore Banks ,
OVDP ,
Related Parties ,
Transfer Pricing
The Organisation for Economic Co-operation and Development (OECD) has issued a policy note document (Note) addressing the tax challenges of the digitalization of the economy under its action plan with respect to base erosion...more
2/4/2019
/ BEPS ,
Controlled Foreign Corporations ,
Corporate Taxes ,
Cross-Border Transactions ,
Digital Services ,
Foreign Tax Credits ,
GILTI tax ,
International Tax Issues ,
Multinationals ,
OECD ,
WTO
On December 13, 2018, proposed regulations (Proposed Regulations) were issued that reduce certain compliance obligations under Sections 1471-1474 (the Foreign Account Tax Compliance Act (FATCA)) of the Internal Revenue Code...more
On December 13, 2018, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued proposed regulations under section 59A of the Internal Revenue Code of 1986, as amended, commonly referred to as...more
On November 28, 2018, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued proposed regulations concerning foreign tax credit determinations and related issues (Proposed Regulations) to take...more
On October 31, 2018, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued proposed regulations (Proposed Regulations) modifying the application of section 956 of the Internal Revenue Code of...more
11/7/2018
/ Controlled Foreign Corporations ,
Corporate Taxes ,
Dividends ,
GILTI tax ,
Internal Revenue Code (IRC) ,
IRS ,
Proposed Regulation ,
Real Estate Investments ,
Registered Investment Companies (RICs) ,
REIT ,
Section 956 ,
Tax Exemptions ,
U.S. Treasury
Public Law 115-97 (the Tax Cuts and Jobs Act (TCJA)) added a new foreign income inclusion rule for global intangible low-taxed income (GILTI) under section 951A. On September 13, 2018, the Department of the Treasury...more
9/25/2018
/ Controlled Foreign Corporations ,
Corporate Taxes ,
Foreign Tax Credits ,
GILTI tax ,
Income Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
Partnerships ,
Proposed Regulation ,
Shareholders ,
Tax Cuts and Jobs Act ,
U.S. Treasury
On August 1, 2018, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued proposed regulations, which were published in the Federal Register on August 9, 2018 (Proposed Regulations),...more