News & Analysis as of

Foreign Earned Income Foreign Corporations

Rivkin Radler LLP

Enough Already – Eliminate Downward Attribution and Accidental CFCs

Rivkin Radler LLP on

It’s Complicated- The Code includes a number of complex rules that are aimed at those overseas business and investment activities of U.S. taxpayers that Congress has determined may result in the improper deferral or...more

Farrell Fritz, P.C.

The Federal Anti-Deferral Rules For Foreign Income –Just A Reminder, There’s No Easy Way Out

Farrell Fritz, P.C. on

It’s Complicated- Coming to grips with the U.S. tax treatment of the foreign-sourced income of a closely held domestic business, and of commercial transactions involving such a business and its related foreign entities,...more

Foodman CPAs & Advisors

Are there conflicting signals from IRS as it relates to Section 965?

IRC Section 965 (Treatment of Deferred Foreign Income Upon Transition to Participation Exemption System of Taxation) was part of the TCJA enacted on December 22, 2017.  ...more

Foodman CPAs & Advisors

IRS “BEEFS UP” Section 965 COMPLIANCE For 2017 And 2018 Returns

Foodman CPAs & Advisors on

On July 2, 2018, the IRS introduced a Compliance Campaign directed at Section 965 (Transition Tax) of the Internal Revenue Code (IRC). In its original launch, the Section 965 Campaign stated that U.S. shareholder are...more

McDermott Will & Emery

IRS Issues Transition Tax Compliance Campaign

McDermott Will & Emery on

On November 4, 2019, the Internal Revenue Service (IRS) announced a new Large Business and International (LB&I) compliance campaign regarding Section’s 965 transition tax under the Tax Cuts and Jobs Act (TCJA). This is one of...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

Farrell Fritz, P.C.

S Corps, CFCs & The Tax Cuts & Jobs Act

Farrell Fritz, P.C. on

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

Farrell Fritz, P.C.

U.S. Taxation Of Foreign Income After Tax Reform

Farrell Fritz, P.C. on

We’ve all heard about the profits that publicly-held U.S. corporations have generated overseas, and how those profits have, until now, escaped U.S. income taxation by virtue of not having been repatriated to the U.S. It...more

Alston & Bird

Tax Cuts and Jobs Act – First Impressions Regarding International Tax Reform

Alston & Bird on

Comprehensive tax reform is moving rapidly, and both the House and the Senate have proposed their own versions of tax reform. Our International Tax and Tax Policy & Regulation Groups investigate the differences between the...more

Jones Day

House of Representatives Releases First Draft of Tax Reform Bill

Jones Day on

The Situation: On November 2, 2017, the House Ways and Means Committee released its first draft of much-anticipated comprehensive U.S. tax reform legislation as the "Tax Cuts and Jobs Act." Chairman Brady’s markup of the bill...more

Foodman CPAs & Advisors

Stay out of TROUBLE: Make sure your CPA is asking you the right QUESTIONS regarding Foreign Accounts!

US International tax is complicated. It often overwhelms US Taxpayers. That is why an international tax specialist CPA is the best choice for the work. Nonetheless, many Taxpayers seek the help of tax return preparers...more

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