GILTI tax, Federal Trade Commission (FTC)

U.S. Tax Legislation Alert: Wyden Bill Proposes…

Fenwick & West LLP on 9/10/2021

Last month, Senate Finance Committee Chair Ron Wyden of Oregon and fellow Finance Committee Democrats Sherrod Brown of Ohio and Mark Warner of Virginia released a draft proposed overhaul of the international tax regime (the...more

Elective GILTI Exclusion for High-Taxed GILTI

McDermott Will & Emery on 8/10/2020

On July 20, 2020, the US Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued final section 951A regulations (“Final Regulations”) on an election to exclude high-tax global intangible low-taxed...more

The GILTI High-Tax Exclusion and the Tested Unit Standard: New Administrative Burdens Await for Taxpayers

McDermott Will & Emery on 8/10/2020

On July 23, 2020, the US Department of the Treasury and the Internal Revenue Service (IRS) published final regulations addressing the global intangible low-taxed income (GILTI) high-tax exclusion (85 FR 44620) (the “Final...more

Proposed Regulations Would Conform Subpart F High-Tax Exception to GILTI High-Tax Exception

McDermott Will & Emery on 8/7/2020

On July 20, 2020, the US Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued proposed regulations (REG-127732-19) (the 2020 Proposed Regulations) that would conform the historic Subpart F...more

Skadden's 2020 Insights

Skadden, Arps, Slate, Meagher & Flom LLP on 1/30/2020

Despite political and economic uncertainties, markets and deal activity were resilient in 2019, and strong fundamentals remain in place heading into 2020. Companies continue to face a challenging litigation and enforcement...more

The New Foreign Tax Credit Proposed Regulations – An Executive Summary

Fenwick & West LLP on 12/13/2018

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