The Global Intangible Low-Taxed Income (GILTI) provisions were enacted as part of the 2017 Tax Cuts and Jobs Act (TCJA). Under the GILTI provisions, a U.S. shareholder essentially is taxed on the active earnings of a...more
As a result of the coronavirus (COVID-19) pandemic, several legislative and regulatory measures have been promulgated in an effort to assist businesses during the economic downturn. Below is a summary of the most important...more
• The U.S. Department of the Treasury has released proposed regulations dealing with the application of the recent U.S. tax reform to U.S. shareholders of a "controlled foreign corporation" (CFC).
• A foreign corporation...more
3/6/2019
/ Controlled Foreign Corporations ,
Corporate Taxes ,
Foreign Earned Income ,
Foreign Tax Credits ,
GILTI tax ,
Income Taxes ,
Proposed Regulation ,
Shareholders ,
Stock Ownership ,
Tax Credits ,
Tax Cuts and Jobs Act ,
Tax Planning ,
U.S. Treasury
President Donald Trump signed the U.S. tax reform bill previously entitled the Tax Cuts and Jobs Act into law on December 22, 2017, enacting comprehensive U.S. tax reform with most provisions becoming effective starting on...more
1/3/2018
/ Base Erosion Tax ,
Capital Gains ,
Carried Interest ,
Corporate Taxes ,
Dividends ,
EBITDA ,
Estate Tax ,
Foreign Corporations ,
Foreign Subsidiaries ,
Foreign Taxpayers ,
Income Taxes ,
International Tax Issues ,
IRS ,
Net Operating Losses ,
New Legislation ,
Pass-Through Entities ,
Royalties ,
Shareholders ,
Small Business ,
Subsidiaries ,
Tax Cuts and Jobs Act ,
Tax Deductions ,
Tax Rates ,
Tax Reform ,
Trump Administration ,
Withholding Tax
President Donald Trump signed the Tax Cuts and Jobs Act into law on December 22, 2017, enacting comprehensive U.S. tax reform with most provisions becoming effective starting on January 1, 2018 (generally until 2025).
The...more
12/28/2017
/ Carried Interest ,
Corporate Taxes ,
Estate Tax ,
Income Taxes ,
Like Kind Exchanges ,
Net Operating Losses ,
New Legislation ,
Pass-Through Entities ,
Property Owners ,
Real Estate Development ,
Tax Cuts and Jobs Act ,
Tax Exemptions ,
Tax Rates ,
Tax Reform ,
Trump Administration
Congress released the "Tax Cuts and Jobs Act" on late Friday evening, Dec. 15, 2017. This version of the bill is the result of a conference committee process to marry the different bills previously passed by the U.S. House of...more
12/20/2017
/ Alternative Minimum Tax ,
Business Taxes ,
Capital Gains ,
Carried Interest ,
Corporate Taxes ,
Depreciation ,
Dividends ,
Estate Tax ,
Foreign Subsidiaries ,
Gift Tax ,
GST ,
Income Taxes ,
IRS ,
Itemized Deductions ,
Net Operating Losses ,
Pass-Through Entities ,
Personal Exemptions ,
Proposed Legislation ,
Section 199 ,
Shareholders ,
Standard Deduction ,
Subpart F ,
Tax Code ,
Tax Credits ,
Tax Rates ,
Tax Reform ,
Trump Administration ,
U.S. Treasury
It has been a busy week in Washington, D.C., as Congress works its way through tax reform. The House Ways and Means Committee completed its "markup" of the House bill this week, paving the way for a floor vote on the measure...more
11/13/2017
/ Alternative Minimum Tax ,
Business Tax Credits ,
Capital Gains ,
Carried Interest ,
Corporate Taxes ,
Death Tax ,
Depreciation ,
Dividends ,
Estate Tax ,
Foreign Corporations ,
Foreign Subsidiaries ,
Gift Tax ,
GST ,
Itemized Deductions ,
Markups ,
Net Operating Losses ,
Pass-Through Entities ,
Personal Exemptions ,
Section 199 ,
Standard Deduction ,
Subpart F ,
Tax Deductions ,
Tax Planning ,
Tax Rates ,
Tax Reform ,
Ways and Means Committee
With Republicans in control of the U.S. Senate, the U.S. House of Representatives and the White House starting in 2017, the federal government is now better positioned to move forward on comprehensive tax reform, with...more
11/29/2016
/ Alternative Minimum Tax ,
Business Taxes ,
Capital Gains ,
Corporate Taxes ,
Depreciation ,
Estate Tax ,
Foreign Subsidiaries ,
Gift Tax ,
GST ,
Life Insurance ,
Mortgage Interest ,
Net Investment Income ,
Net Operating Losses ,
Personal Exemptions ,
S-Corporation ,
Subpart F ,
Tax Credits ,
Tax Deductions ,
Tax Rates ,
Tax Reform ,
Trump Administration
Lately, the media has focused on tax inversions, most recently when Burger King announced that it will purchase Tim Hortons, a Canadian company, but what are they?...more