Recently released Revenue Procedure 2021-26 (the Revenue Procedure) provides taxpayers with guidance regarding accounting method changes made on behalf of foreign corporations. The Revenue Procedure:
..Allows controlled...more
5/27/2021
/ Accounting Methods ,
Audits ,
Controlled Foreign Corporations ,
Depreciation ,
Foreign Corporations ,
GAAP ,
GILTI tax ,
Internal Revenue Code (IRC) ,
IRS ,
Revenue Procedures ,
Tax Cuts and Jobs Act ,
Taxable Income ,
U.S. Treasury
The Tax Cuts and Jobs Acts (TCJA) repealed § 958(b)(4) of the Code, which prevented downward attribution of stock ownership from a foreign person to a US person. That repeal has resulted in many foreign corporations being...more
10/14/2019
/ Controlled Foreign Corporations ,
Corporate Taxes ,
Domestic Corporations ,
Foreign Entities ,
GILTI tax ,
Internal Revenue Code (IRC) ,
IRS ,
Proposed Regulation ,
Repeal ,
Reporting Requirements ,
Revenue Procedures ,
Safe Harbors ,
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