AGG Talks: Cross-Border Business - U.S. Tax Considerations for Scaling Across Borders
Podcast: Illinois Tool Works Inc. & Subsidiaries v. Commissioner of Internal Revenue
Discover the latest global developments and planning opportunities to stay ahead of the curve at McDermott’s Tax Symposium 2024. Join us in Chicago for a full day of programming designed to equip corporate tax leaders with...more
In this episode, Mike Burke, AGG Corporate partner and leader of the Ireland & Northern Ireland practice, explores U.S. tax considerations for foreign businesses scaling to the U.S., including issues such as the branch...more
For years, section 962 was a relatively obscure tax-planning mechanism. The Tax Cuts & Jobs Act, however, changed that, pushing the so-called section 962 election into vogue. Section 962 allows an individual shareholder of a...more
Tax Litigation: The Week of March 14, 2022, through March 18, 2022 Hamilton v. Comm’r, T.C. Memo. 2022-21 | March 15, 2022 |Urda, J. | Dkt. No. 139-19L Pickens Decorative Stone, LLC v. Comm’r, T.C. Memo. 2022-22 | March 17,...more
In the international tax context, the source of a taxpayer’s income can have significant implications. The source of income may determine whether a taxpayer qualifies for a foreign tax credit with respect to the income. Or,...more
U.S. taxpayers are generally taxed on their worldwide income. But what happens when that income is also taxed by another country? The Internal Revenue Code’s primary mechanism to alleviate this double taxation of income is...more
The House Ways and Means Committee advanced key tax reform proposals on September 15 that would increase taxes for corporations and high-income individuals. Several tax reform proposals are under consideration as part of...more
As you may be aware, the House Ways and Means Committee recently approved a multitrillion-dollar tax package (the “Proposal”) that has significant tax impact on both individuals and corporations. ...more
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
On December 2, 2019, Treasury and the IRS released final and proposed regulations on the foreign tax credit. As expected, the final regulations finalize the 2018 proposed regulations relating mainly to the Tax Cuts and Jobs...more
Final regulations relating to the determination of the foreign tax credit following the Tax Cuts and Jobs Act were released earlier this month. Though largely similar to the proposed regulations, taxpayers may be interested...more
The Treasury Department and the IRS have issued highly anticipated guidance in the area of stewardship expenses and R&D expenses. The 2019 Proposed Regulations also provide extensive guidance on allocating and apportioning...more
On December 2, 2019, the U.S. Department of the Treasury (“Treasury”) and the Internal Revenue Service (“IRS”) issued a pre-published version of final regulations (the “Final Regulations”) providing guidance with respect to...more
In a significant reversal of prior policy, on June 20, 2019, the New York State Assembly and New York State Senate passed Senate Bill 6615, which will exclude 95% of a corporate franchise taxpayer’s gross global intangible...more
The 2017 Tax Act added a new tax on US shareholders of controlled foreign corporations (“CFCs”), the tax on Global Intangible Low-Taxed Income (“GILTI”). GILTI often includes active business income and thus has a widespread...more
Estonia, the small Baltic country of just 1.3 million people situated halfway between Sweden and Russia, was named “the most advanced digital society in the world” by Wired magazine. According to recent figures, Estonian...more
2018 was a very active year for tax developments. The big story was the application of the substantial reforms of the Tax Cuts and Jobs Act of 2017, which took initial effect in 2018. But there were several other developments...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
The Organisation for Economic Co-operation and Development (OECD) has issued a policy note document (Note) addressing the tax challenges of the digitalization of the economy under its action plan with respect to base erosion...more
On November 28, 2018, the Internal Revenue Service (IRS) and the US Department of the Treasury released proposed regulations (REG-105600-18) that address the calculation of a corporate US shareholder’s deemed paid foreign tax...more
On November 28, 2018, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued proposed regulations concerning foreign tax credit determinations and related issues (Proposed Regulations) to take...more
Public Law 115-97 (the Tax Cuts and Jobs Act (TCJA)) added a new foreign income inclusion rule for global intangible low-taxed income (GILTI) under section 951A. On September 13, 2018, the Department of the Treasury...more
• The Tax Cuts and Jobs Act (Tax Act), signed into law on Dec. 22, 2017, made significant changes to the manner in which U.S. corporate and individual taxpayers are taxed on income from international operations. • The Tax...more
Pro “C” Corporation Bias? Although closely-held businesses have generally welcomed the TCJA’s amendments to the Code relating to the taxation of business income, many are also frustrated by the complexity of some of these...more
Prior to the Tax Act, the principal method for avoiding the double taxation of overseas corporate earnings—once by the local country and a second time by the United States as the multinational's home country—was the foreign...more