The new regulations proposed in September under Section 382(h) regarding built-in-gain raise several international tax issues that companies planning for post-acquisition integration of loss corporations should be aware of....more
10/7/2019
/ Acquisitions ,
Built-In Gains ,
Change of Ownership ,
Corporate Taxes ,
GILTI tax ,
IRS ,
Loss Limitation Rules ,
Mergers ,
Net Operating Losses ,
New Rules ,
Proposed Regulation ,
Section 382 ,
Tax Exemptions ,
Tax Planning
Released on November 30, 2018, the foreign tax credit proposed regulations provide a comprehensive new framework for calculating the foreign tax credit in light of several changes made by the Tax Cuts and Jobs Act (TCJA or...more
12/13/2018
/ Allocation of Funds ,
Banking Sector ,
Books & Records ,
CFC ,
Controlled Foreign Corporations ,
Corporate Taxes ,
Federal Taxes ,
Federal Trade Commission (FTC) ,
Financial Institutions ,
Foreign Banks ,
Foreign Corporations ,
Foreign Tax ,
GILTI tax ,
Income Taxes ,
Interest Payments ,
IRS ,
Multinationals ,
New Rules ,
Parent Corporation ,
Partnerships ,
Proposed Regulation ,
Royalties ,
Stocks ,
Subpart F ,
Tax Credits ,
Tax Cuts and Jobs Act ,
Tax Exemptions ,
Tax Planning ,
Tax Rates ,
Tax Reform ,
Tax Returns ,
Taxable Distributions ,
U.S. Treasury
The application of §1248 and §338(g) in the context of the purchase or sale of a controlled foreign corporation (CFC) has long been one of the most complex areas of the tax code. The recently enacted tax reform act — herein,...more
9/18/2018
/ Asset Management ,
C-Corporation ,
Controlled Foreign Corporations ,
Corporate Taxes ,
Federal Taxes ,
GILTI tax ,
Income Taxes ,
International Tax Issues ,
IRS ,
New Rules ,
Partnerships ,
Pass-Through Entities ,
Private Equity Firms ,
Shareholders ,
Stock Purchase Agreement ,
Stock Sale Agreements ,
Stocks ,
Tax Code ,
Tax Cuts and Jobs Act ,
Tax Deferral ,
Tax Planning ,
Tax Reform