The final regulations addressing the GILTI high-tax exception retain the general approach of the proposed regulations with some simplifying changes.
Key Points:
..Taxpayers can elect on an annual basis whether to...more
But Holding Period and Other Requirements Add Complexity -
On October 31, 2018, the US Treasury and Internal Revenue Service issued proposed regulations (the Proposed Regulations) that would eliminate, in most...more
Certainty regarding characterization of intercompany transactions remains a priority after US tax reform, opinion highlights importance of established pattern of conduct.
On August 6, 2018, the US Tax Court decided...more
Introduction and Overview -
The Tax Cuts and Jobs Act (“TCJA”) resulted in the most sweeping changes to the Internal Revenue Code (the “Code”) in decades and will result in countless articles and commentary to address the...more
The new tax rules are expected to have an immediate impact on leveraged companies and leveraged finance transactions.
On December 22, 2017, President Trump signed into law the “Tax Cuts and Jobs Act” (the Act).1 This...more
New regulations expand prior guidance reducing tax benefits of inversions. Proposed debt-equity rules will impact even routine intercompany transactions.
On April 4, 2016, the US Department of the Treasury (Treasury) and...more
4/21/2016
/ Acquisitions ,
Anti-Inversion Regulations ,
Controlled Foreign Corporations ,
Controlled Groups ,
Corporate Taxes ,
De Minimus Quantity Exemption ,
Dividends ,
Foreign Corporations ,
Inversion ,
IRS ,
Multinationals ,
Proposed Regulation ,
Related Parties ,
Stocks ,
U.S. Treasury