In the late 1990s and early 2000s, the IRS was confronted with a proliferation of corporate transactions that it viewed as aggressive tax shelters. Relying on the authority Congress delegated through Section 6011(a), the IRS...more
6/13/2024
/ Administrative Procedure Act ,
Conservation Easements ,
Corporate Taxes ,
Easements ,
IRS ,
Proposed Regulation ,
Reporting Requirements ,
Tax Appeals ,
Tax Avoidance ,
Tax Court ,
Tax Penalties ,
Tax Shelters
A previous Holland & Knight alert provided an overview of corporate and individual income tax increases as detailed in the U.S. Department of the Treasury May 2021 "Green Book." (See "Biden Administration's FY 2022 Budget and...more
6/11/2021
/ Biden Administration ,
Controlled Foreign Corporations ,
Corporate Taxes ,
Foreign Tax ,
Foreign Tax Credits ,
GILTI tax ,
Green Book ,
International Tax Issues ,
Multinationals ,
OECD ,
Tax Cuts and Jobs Act ,
Tax Rates ,
Tax Reform ,
U.S. Treasury
By way of background, the budget that the president submits to Congress contains estimates of federal government income and spending for the upcoming fiscal year and also recommends funding levels for the federal government....more
6/4/2021
/ Appropriations Bill ,
Biden Administration ,
Corporate Taxes ,
Federal Budget ,
Green Book ,
Internal Revenue Code (IRC) ,
IRS ,
OECD ,
Proposed Legislation ,
Tax Reform ,
U.S. Treasury
The Global Intangible Low-Taxed Income (GILTI) provisions were enacted as part of the 2017 Tax Cuts and Jobs Act (TCJA). Under the GILTI provisions, a U.S. shareholder essentially is taxed on the active earnings of a...more