News & Analysis as of

GILTI tax CARES Act

ArentFox Schiff

“Should Five Percent Appear Too Small, Be Thankful I Don’t Take It All”: Ways and Means Committee Advances Tax Increase and Reform...

ArentFox Schiff on

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

Franczek P.C.

The First 100 Days of the Biden Administration: Labor and Employment Activity (UPDATED)

Franczek P.C. on

In week eleven, the Biden administration’s labor and employment activity includes the introduction of the American Jobs Plan, the extension of the Paycheck Protection Program, employment policy changes at the Department of...more

Pierce Atwood LLP

Maine Governor’s Proposed Supplemental Budget – Federal (Non)Conformity Summarized

Pierce Atwood LLP on

Maine Governor Janet Mills submitted a supplemental budget, as amended by a change package submitted on January 25, 2021. The supplemental budget is notable for its retroactive conformity to the Internal Revenue Code (IRC) as...more

McDermott Will & Emery

Weekly IRS Roundup August 31 – September 4, 2020

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 31, 2020 – September 4, 2020. Additionally, for continuing updates on the tax impact of...more

Eversheds Sutherland (US) LLP

Second time’s the charm? New proposed section 163(j) regulations treat electing CFC groups as a single corporation and eliminate...

Significant provisions of the 2020 Proposed Regulations addressing the application of section 163(j) to foreign corporations and their shareholders include: ..An election under which a controlled foreign corporation (CFC)...more

Fenwick & West LLP

The FDII Final Regulations Are Here: An Executive Summary and Observations

Fenwick & West LLP on

Treasury and the IRS released final section 250 regulations on July 9, 2020, primarily focused on the deduction for foreign-derived intangible income (FDII). The final regulations make significant revisions to the proposed...more

A&O Shearman

Tax Planning after the GILTI and Subpart F High-Tax Exceptions

A&O Shearman on

On July 23, 2020, the U.S. Department of Treasury (“Treasury”) and the Internal Revenue Service (IRS) finalized regulations (T.D. 9902) with respect to the global intangible low-taxed income (GILTI) high-tax exception (“Final...more

McDermott Will & Emery

Weekly IRS Roundup July 20 – July 24, 2020

McDermott Will & Emery on

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of July 20, 2020 – July 24, 2020... July 20, 2020: The IRS published a news release on...more

McDermott Will & Emery

CARES Act Could Result in Taxation of More GILTI in New Jersey

The federal stimulus bill (the CARES Act), HR 748, which was signed into law by President Trump on March 27, includes certain corporate income tax provisions designed to provide relief to corporate taxpayers. One such...more

Skadden, Arps, Slate, Meagher & Flom LLP

CARES Act Tax Considerations

The Coronavirus Aid, Relief, and Economic Security Act (CARES Act) was signed into law on March 27, 2020, representing the so-called “Phase 3” of the response to the COVID-19 pandemic, as discussed in our client alert “CARES...more

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