Last month, Senate Finance Committee Chair Ron Wyden of Oregon and fellow Finance Committee Democrats Sherrod Brown of Ohio and Mark Warner of Virginia released a draft proposed overhaul of the international tax regime (the...more
Treasury and the IRS released final section 250 regulations on July 9, 2020, primarily focused on the deduction for foreign-derived intangible income (FDII). The final regulations make significant revisions to the proposed...more
8/17/2020
/ Applicability Date ,
Arms Export Control Act ,
CARES Act ,
Cost of Goods Sold (COGS) ,
Foreign Derived Intangible Income (FDII) ,
Foreign Persons ,
Foreign Sales ,
GILTI tax ,
Internal Revenue Code (IRC) ,
IRS ,
New Regulations ,
New Rules ,
Required Documentation ,
U.S. Treasury
The Tax Cuts and Jobs Act (TCJA) repealed the long-standing “50/50” sourcing rule for United States exporters of manufactured products. Under the new rules, which source income of a “producer” solely to the place of...more
1/29/2020
/ Cross-Border Transactions ,
Exports ,
Foreign Derived Intangible Income (FDII) ,
Foreign Tax Credits ,
Imports ,
Inventory ,
IRS ,
Manufacturers ,
Natural Resources ,
Pass-Through Entities ,
Proposed Regulation ,
Qualified Business Income ,
Resource Extraction ,
Section 199A ,
Tax Cuts and Jobs Act ,
U.S. Treasury