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Tax Planning after the GILTI and Subpart F High-Tax Exceptions

On July 23, 2020, the U.S. Department of Treasury (“Treasury”) and the Internal Revenue Service (IRS) finalized regulations (T.D. 9902) with respect to the global intangible low-taxed income (GILTI) high-tax exception (“Final...more

8/4/2020  /  CARES Act , GILTI tax , Treasury

Tax Planning for Multinational Borrowers During the COVID-19 Crisis

With the likely increased borrowings or refinancing of debt as a result of the COVID-19 crisis, multinational companies should consider the impact of changes in U.S. tax law made in 2018. As a result of these changes, U.S....more

Final and Proposed TCJA Foreign Tax Credit Regulations Create Traps and Opportunities

On December 2, 2019, the U.S. Department of the Treasury (“Treasury”) and the Internal Revenue Service (“IRS”) issued a pre-published version of final regulations (the “Final Regulations”) providing guidance with respect to...more

Guidance on CFC ‘Downward Attribution Rules’ Provides Limited Relief to US Taxpayers

On October 1, 2019, the Internal Revenue Service (IRS) issued Revenue Procedure 2019-40 (Revenue Procedure) and proposed regulations (Proposed Regulations) addressing issues related to the repeal of section 958(b)(4) by the...more

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