On May 28, 2021, the US Department of the Treasury (Treasury) released the Fiscal Year (FY) 2022 budget and Green Book, which provides detailed insights into the proposals of US President Joe Biden’s recently released...more
6/22/2021
/ Anti-Inversion Regulations ,
Base Erosion and Anti-Abuse Tax (BEAT) ,
Biden Administration ,
Country-by-Country ,
Federal Budget ,
Fiscal Year ,
Foreign Tax Credits ,
GILTI tax ,
Green Book ,
International Tax Issues ,
IRS ,
Subpart F ,
Tax Incentives ,
U.S. Treasury
On July 9, 2020, the US Department of the Treasury (Treasury) and Internal Revenue Service (IRS) released Final Regulations (Final Regulations) that provide guidance on the section 250 deduction for foreign-derived intangible...more
Final and new proposed regulations on the base erosion anti-abuse tax (the BEAT) under section 59A have been issued by the United States Treasury and IRS, providing clarifications and some relief tied to inbound liquidations...more
12/18/2019
/ Anti-Abuse Rule ,
Base Erosion and Anti-Abuse Tax (BEAT) ,
Base Erosion Tax ,
Business Judgment Rule ,
Corporate Taxes ,
Final Rules ,
GILTI tax ,
Income Taxes ,
IRS ,
New Regulations ,
Popular ,
Proposed Regulation ,
Revenue Procedures ,
Subpart F ,
Treasury Regulations
Health Care Private Equity Investments in India -
A flurry of recent private equity (PE) investments in the Indian health care sector demonstrates strong investor appetite and opportunities.
India is one of the fastest...more
The Tax Cuts and Jobs Act introduced an important new benefit to US corporations that own 10 percent or more of a foreign corporation. Specifically, a full participation exemption has been enacted that exempts certain foreign...more
6/19/2018
/ Controlled Foreign Corporations ,
Corporate Taxes ,
Dividends ,
Foreign Corporations ,
Foreign Subsidiaries ,
GILTI tax ,
Shareholders ,
Tax Cuts and Jobs Act ,
Tax Liability ,
Tax Planning ,
Tax Reform