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
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 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
• 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
11/9/2018
/ Controlled Foreign Corporations ,
Corporate Financing ,
Dividends ,
IRS ,
Limited Liability Company (LLC) ,
Partnerships ,
Proposed Regulation ,
Section 956 ,
Shareholders ,
Subsidiaries ,
Tax Cuts and Jobs Act
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
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