The Tax Cuts and Jobs Act (TCJA) repealed the long-standing “50/50” sourcing rule for United States exporters of manufactured products.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
This document discusses Notice 2018-26, the third IRS Notice providing guidance on the new mandatory repatriation tax under § 965.
Most importantly, the Notice sets forth extensive anti-avoidance rules in respect of...more