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Corporate Taxes GILTI tax Foreign Corporations

Freeman Law

El IRS actualiza reglas sobre los ajustes a la base gravable en las distribuciones a mitad de año por las CFC para evitar las...

Freeman Law on

Durante años, había existido incertidumbre entre los profesionistas que se dedican a la materia fiscal sobre sobre si las ganancias obtenidas a mitad de año por una Corporación Extranjera Controlada (por sus siglas en inglés,...more

Skadden, Arps, Slate, Meagher & Flom LLP

GILTI Conscience Podcast | Pillar Two Analysis: An Asia Pacific Viewpoint

Our latest “GILTI Conscience” podcast featured Deloitte international tax partner Sam Gordon, who joined hosts Nate Carden and David Farhat for an in-depth look at Asia Pacific’s perspective on Pillar Two, particularly from...more

Skadden, Arps, Slate, Meagher & Flom LLP

GILTI Conscience Podcast | Gearing Up for Pillar Two

Our “GILTI Conscience” team was joined by colleagues Paul Oosterhuis and Eric Sensenbrenner to discuss what companies can expect now that Pillar Two implementation is becoming a reality. ...more

Freeman Law

Section 245A Overview and Requirements

Freeman Law on

Section 245A: Tax Efficient Repatriation of a Foreign Subsidiary’s Earnings - Freeman Law frequently advises U.S. multinational corporations. United States-based international businesses are subject to complex reporting...more

Freeman Law

The Section 962 Election

Freeman Law on

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

Bowditch & Dewey

Impact of House Ways and Means Tax Proposals for International Operations

Bowditch & Dewey on

In this final blog post on the House Ways and Means Tax Bill, we address the international tax proposals in the Bill, JCX-43-21. The international tax proposals are fewer in number than the domestic and transfer tax...more

Holland & Knight LLP

Biden Administration's Made in America Tax Plan: Interaction with OECD Inclusive Framework

Holland & Knight LLP on

The American Jobs Plan is a proposal to increase investment in infrastructure, the production of clean energy, the care economy and other priorities. The Made in America Tax Plan (Tax Plan) is the vehicle to pay for the...more

Alston & Bird

From Obscurity to Spotlight: The Section 962 Election

Alston & Bird on

Our International Tax Group addresses an election under Section 962 available to individual U.S. shareholders of certain foreign corporations to be taxed as a C corporation, which before tax reform was a rarely utilized and...more

Skadden, Arps, Slate, Meagher & Flom LLP

The Tax Cuts and Jobs Act’s Impact on Cross-Border Transactions

Two years after the enactment of the Tax Cuts and Jobs Act (TCJA), the most significant tax reform enacted in a generation, taxpayers continue to encounter substantial uncertainty arising from interpretations of new statutory...more

Fenwick & West LLP

PFIC: What U.S. Investment Funds Should be Particularly Aware of and Newly Proposed Regulations

Fenwick & West LLP on

U.S.-based venture capital and other funds that invest in foreign companies must be careful to avoid the passive foreign investment company (PFIC) rules, which could substantially increase the tax owed on exit for U.S....more

Proskauer - Tax Talks

IRS provides very modest relief from downward attribution resulting from the repeal of section 958(b)(4)

Proskauer - Tax Talks on

On October 2, 2019, the Internal Revenue Service (“IRS”) and the U.S. Department of the Treasury (the “Treasury”) issued Revenue Produce 2019-40 (the “Revenue Procedure”) and proposed regulations (the “Proposed Regulations”)...more

Alston & Bird

Down the Rabbit Hole: Guidance Addressing Downward Attribution After Repeal of Section 958(b)(4)

Alston & Bird on

The IRS released Proposed Regulations and a Revenue Procedure addressing the Tax Cuts and Jobs Act’s repeal of Section 958(b)(4). Our International Tax Group explores how this guidance affects numerous provisions of the Code....more

McDermott Will & Emery

Weekly IRS Roundup September 30 – October 4, 2019

McDermott Will & Emery on

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of September 30 – October 4, 2019. September 30, 2019: The IRS published a draft of the tax year...more

A&O Shearman

Guidance on CFC ‘Downward Attribution Rules’ Provides Limited Relief to US Taxpayers

A&O Shearman on

On October 1, 2019, the Internal Revenue Service (IRS) issued Revenue Procedure 2019-40 (Revenue Procedure) and proposed regulations (Proposed Regulations) addressing issues related to the repeal of section 958(b)(4) by the...more

Wilson Sonsini Goodrich & Rosati

Corporate Tax 2019 - Seventh Edition - USA Chapter

Since December 22, 2017, corporate tax practitioners in the United States have been predominantly focused on the impact of legislation commonly known as the Tax Cuts and Jobs Act (the “Act”), which was signed into law on that...more

McDermott Will & Emery

Weekly IRS Roundup August 19 – 23, 2019

McDermott Will & Emery on

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of August 19 – 23, 2019. August 20, 2019: The IRS released a proposed regulation that provides...more

Jones Day

Warning: U.S. Tax Regulations Impact Completed Foreign Sales Retroactively and Domestic Partnerships

Jones Day on

The Situation: On June 14, 2019, the IRS and U.S. Treasury released more than 500 pages of proposed, temporary, and final regulations addressing the taxation of U.S.-controlled foreign corporations. The Development:...more

A&O Shearman

Final GILTI Regulations and Proposed Regulations on Subpart F Income and GILTI Bring Relief to Private Equity and Other...

A&O Shearman on

On June 14, 2019, the IRS and Treasury finalized the global intangible low-taxed income (GILTI) regulations (T.D. 9866) and issued proposed regulations (REG-101828-19) that will provide significant relief to investors in...more

Cole Schotz

Code §962 Election Is An Option For GILTI Planning

Cole Schotz on

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

Proskauer - Tax Talks

Proposed FDII Regulations under Section 250

Proskauer - Tax Talks on

On March 4, 2019, the Internal Revenue Service (the “IRS”) and the Department of the Treasury (the “Treasury”) released proposed regulations (the “Proposed Regulations”) regarding the deduction for “foreign-derived intangible...more

Farrell Fritz, P.C.

Checked The Box? Feeling GILTI Now?

Farrell Fritz, P.C. on

Once Upon A Time- I recently recalled a client that was referred to us a few years back, shortly before it was acquired by a larger company. The client was closely held by U.S. individuals and by an S corporation, and was...more

Bilzin Sumberg

Looking for a GILTI-Free Structure? Try Estonia

Bilzin Sumberg on

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

Farrell Fritz, P.C.

U.S. Individuals Electing To Be Treated As Corporations: American Werewolves?

Farrell Fritz, P.C. on

The Tax Cuts and Jobs Act has been called a lot of things by a lot of different people. Certain provisions of the Act, however,coupled with recently proposed regulations thereunder, may result in its being known as the...more

Eversheds Sutherland (US) LLP

The Last Piece of the Puzzle - the Section 250 Proposed Regulations

Public Law 115-97 (the Tax Cuts and Jobs Act) added a new foreign income inclusion rule for global intangible low-taxed income (GILTI) under section 951A. The Tax Cuts and Jobs Act also added section 250, which permits...more

Foodman CPAs & Advisors

Understanding How to Compute a U.S. shareholder’s GILTI inclusion

The Tax Cuts and Jobs Act added section 951A to the Internal Revenue Code. This new section requires a U.S. shareholder of a Controlled Foreign Corporation (CFC) to include in gross income the shareholder’s Global Intangible...more

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