As the U.S. Senate is set to consider President Trump's domestic policy bill, non-U.S.-based multinational businesses and non-U.S. investors are preparing for wholesale changes to the U.S. international tax landscape,...more
6/5/2025
/ Base Erosion and Anti-Abuse Tax (BEAT) ,
Controlled Foreign Corporations ,
Corporate Taxes ,
Foreign Derived Intangible Income (FDII) ,
Foreign Investment ,
GILTI tax ,
International Tax Issues ,
Multinationals ,
Proposed Legislation ,
Tax Cuts and Jobs Act ,
Tax Planning ,
Tax Rates ,
Tax Reform ,
Trump Administration ,
U.S. Treasury
On January 24, 2022, the IRS issued proposed regulations that impact certain elections available to U.S. taxpayers with respect to their indirect interests in passive foreign investment companies (PFICs).
Pursuant to the...more