A U.S. shareholder of a foreign corporation generally is not subject to U.S. federal income tax on the income of the foreign corporation until the shareholder receives an actual distribution from the corporation. However,...more
The Internal Revenue Service (IRS) has provided taxpayers with needed relief by delaying the due dates with respect to various filings and payments during the coronavirus (COVID-19) pandemic. This relief has been announced in...more
• The U.S. Department of the Treasury has released proposed regulations dealing with the application of the recent U.S. tax reform to U.S. shareholders of a "controlled foreign corporation" (CFC).
• A foreign corporation...more
3/6/2019
/ Controlled Foreign Corporations ,
Corporate Taxes ,
Foreign Earned Income ,
Foreign Tax Credits ,
GILTI tax ,
Income Taxes ,
Proposed Regulation ,
Shareholders ,
Stock Ownership ,
Tax Credits ,
Tax Cuts and Jobs Act ,
Tax Planning ,
U.S. Treasury
President Donald Trump signed the U.S. tax reform bill previously entitled the Tax Cuts and Jobs Act into law on December 22, 2017, enacting comprehensive U.S. tax reform with most provisions becoming effective starting on...more
1/3/2018
/ Base Erosion Tax ,
Capital Gains ,
Carried Interest ,
Corporate Taxes ,
Dividends ,
EBITDA ,
Estate Tax ,
Foreign Corporations ,
Foreign Subsidiaries ,
Foreign Taxpayers ,
Income Taxes ,
International Tax Issues ,
IRS ,
Net Operating Losses ,
New Legislation ,
Pass-Through Entities ,
Royalties ,
Shareholders ,
Small Business ,
Subsidiaries ,
Tax Cuts and Jobs Act ,
Tax Deductions ,
Tax Rates ,
Tax Reform ,
Trump Administration ,
Withholding Tax
President Donald Trump signed the Tax Cuts and Jobs Act into law on December 22, 2017, enacting comprehensive U.S. tax reform with most provisions becoming effective starting on January 1, 2018 (generally until 2025).
The...more
12/28/2017
/ Carried Interest ,
Corporate Taxes ,
Estate Tax ,
Income Taxes ,
Like Kind Exchanges ,
Net Operating Losses ,
New Legislation ,
Pass-Through Entities ,
Property Owners ,
Real Estate Development ,
Tax Cuts and Jobs Act ,
Tax Exemptions ,
Tax Rates ,
Tax Reform ,
Trump Administration
Congress released the "Tax Cuts and Jobs Act" on late Friday evening, Dec. 15, 2017. This version of the bill is the result of a conference committee process to marry the different bills previously passed by the U.S. House of...more
12/20/2017
/ Alternative Minimum Tax ,
Business Taxes ,
Capital Gains ,
Carried Interest ,
Corporate Taxes ,
Depreciation ,
Dividends ,
Estate Tax ,
Foreign Subsidiaries ,
Gift Tax ,
GST ,
Income Taxes ,
IRS ,
Itemized Deductions ,
Net Operating Losses ,
Pass-Through Entities ,
Personal Exemptions ,
Proposed Legislation ,
Section 199 ,
Shareholders ,
Standard Deduction ,
Subpart F ,
Tax Code ,
Tax Credits ,
Tax Rates ,
Tax Reform ,
Trump Administration ,
U.S. Treasury
At midnight on December 31, 2012, the United States briefly fell off of the much-anticipated and highly publicized "fiscal cliff," with income tax rates rising on most taxpayers and a host of substantial spending cuts...more