Robert Chase II

Eversheds Sutherland (US) LLP

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High time: Final and proposed regulations rework high-tax rule for GILTI and subpart F

Recently released final regulations provide some relief to taxpayers that are subject to high foreign taxes on their global intangible low-taxed income (GILTI), but whether the GILTI high-tax exclusion is beneficial to any...more

8/28/2020 / Controlled Foreign Corporations , Corporate Taxes , Final Rules , GILTI tax , Income Taxes , IRS , Subpart F

No rest for the weary - final regulations continue to target inversions without major changes

INTRODUCTION - On July 11, 2018, Treasury and the Internal Revenue Service (IRS) published final inversion regulations (TD 9834) which are largely consistent with the temporary (T.D. 9761) and proposed regulations...more

7/19/2018 / Chamber of Commerce , Corporate Taxes , Final Rules , Foreign Corporations , Internal Revenue Code (IRC) , Inversion , IRS , OMB , Tax Avoidance , U.S. Treasury

Branching Out: Nonfunctional Currency Branch Regulations Targeted for Burden Reduction

On October 2, 2017, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued Notice 2017-57 (the Notice) announcing that Treasury and the IRS: - Are considering changes to the final...more

10/13/2017 / Corporate Taxes , Final Rules , IRS , Reporting Requirements , U.S. Treasury

Final Regulations Impose Reporting Obligations on Foreign-Owned Domestic Disregarded Entities

Amid the Panama Papers leak and international concern that foreign persons were concealing assets through U.S. entities that are disregarded for U.S. federal income tax purposes, the Internal Revenue Service (IRS) and the...more

12/16/2016 / Disregarded Entities , Final Rules , Foreign-Owned Corporations , IRS , U.S. Treasury

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