Latest Posts › Shareholders

Share:

The GILTI High-Tax Exception: Is it a Viable Planning Option?

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

Tax Court Upholds Application of Subpart F Manufacturing Branch Rule

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

Relief on the Way to U.S. Individuals Owning Stock in a "Controlled Foreign Corporation" - Treasury Department's Proposed...

• 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

U.S. Corporate Financing Transactions Facilitated by IRS Proposed Regulation

• The Internal Revenue Service has issued a proposed regulation that in many cases should eliminate the detrimental U.S. tax consequences to a U.S. corporation under Section 956 of the Internal Revenue Code when the...more

Main Effects of U.S. Tax Reform on Foreign Taxpayers

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

6 Results
 / 
View per page
Page: of 1

"My best business intelligence, in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:
*By using the service, you signify your acceptance of JD Supra's Privacy Policy.
- hide
- hide