News & Analysis as of

Income Taxes › Internal Revenue Service › GILTI tax

Income taxes are taxes that are collected on the individual earnings of persons or entities. Depending on the jurisdiction, income taxes are calculated and collected in a variety of ways. Some tax systems collect... more +
Income taxes are taxes that are collected on the individual earnings of persons or entities. Depending on the jurisdiction, income taxes are calculated and collected in a variety of ways. Some tax systems collect income taxes based on a progressive scheme, while others may utilize a proportional or regressive framework. less -
Holland & Knight LLP

Moore Thoughts: An Incremental Opinion from the U.S. Supreme Court

Holland & Knight LLP on

The U.S. Supreme Court on June 20, 2024, ruled 7-2 that Section 965 of the Internal Revenue Code, as revised by the law known as the Tax Cuts and Jobs Act, is constitutional. The issue presented to the Court in Moore v....more

Skadden, Arps, Slate, Meagher & Flom LLP

GILTI Conscience Podcast | Spotlight Series: A Celebration of Pride Month With IRS Veteran De Lon Harris

Skadden, Arps, Slate, Meagher & Flom LLP on

In celebration of Pride Month, tax senior advisor De Lon Harris joins Eman Cuyler and Stefane Victor on “GILTI Conscience,” where he discusses his life and career as a gay professional. De Lon talks about his 30-plus years at...more

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 | Inside the IRS: A Conversation With Former Agency Officials

Skadden, Arps, Slate, Meagher & Flom LLP on

Tax of counsel Fred Goldberg and senior advisor for tax resolution strategies De Lon Harris, both formerly of the IRS, joined the hosts of “GILTI Conscience” for a comprehensive look at current developments at the agency,...more

Holland & Hart LLP

Court News: Economic Substance Doctrine Nullifies Transaction

Holland & Hart LLP on

The IRS won a major economic substance case on October 31. A federal district court in Liberty Global, Inc. v. United States, No. 20-cv-03501 (D. Colo.), found that a planned corporate transaction lacked economic substance. ...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

[Webinar] The Freeman Law International Tax Symposium - October 20th - 21st, 9:00 am - 5:00 pm CST

Freeman Law on

Join leading tax experts from across the globe, as we discuss tax trends that are reshaping international taxation - AN EXPERIENCE UNLIKE ANY OTHER - Find yourself on the cutting-edge of international tax law, with...more

McDermott Will & Emery

International News: Spotlight on Tax

McDermott Will & Emery on

INTRODUCTION TO US TAXATION OF NFTS - Despite Non Fungible Token (NFT) sales hitting nearly US$21 billion by the end of 2021, making NFTs almost as valuable as the global art market, they are currently completely ignored...more

Freeman Law

Final Regulations on Stock Owned by Domestic Partnerships under Subpart F

Freeman Law on

On January 25, 2022, the Internal Revenue Services issued final regulations relating to the treatment of stock owned by domestic partnerships under certain provisions of subpart F of the Internal Revenue Code (“Subpart F”). ...more

McDermott Will & Emery

Extending the Statute of Limitations for Assessing Federal Tax

McDermott Will & Emery on

We previously provided an overview of the time limits imposed on the Internal Revenue Service (IRS) for assessing federal tax. The general rule is that the IRS must assess tax within three years from the later of the due date...more

McDermott Will & Emery

Weekly IRS Roundup November 8 – November 12, 2021

McDermott Will & Emery on

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of November 8, 2021 – November 12, 2021... November 9, 2021: The IRS released a Treasury Decision,...more

Freeman Law

Congress Readies New Round of Tax Increases

Freeman Law on

The House Committee of Ways and Means (the “House”) has been busy the last few days. Indeed, the House continues to mark up and work through potential revenue raisers (i.e., tax increases) to help pay for recent legislative...more

Freeman Law

[Webinar] Freeman Law International Tax Symposium – General Attendee - November 18th - 19th, 8:00 am - 5:00 pm CST

Freeman Law on

Join leading tax experts from across the globe, as we discuss tax trends that are reshaping international taxation - An Experience Unlike Any Other - Find yourself on the cutting-edge of international tax law, with...more

McDermott Will & Emery

Kansas Decouples from GILTI and 163j

McDermott Will & Emery on

Yesterday afternoon the Kansas legislature overrode Governor Laura Kelly’s veto of Senate Bill (SB) 50, effectively enacting the provisions of the bill into law. Among those are provisions decoupling from certain Tax Cuts and...more

McDermott Will & Emery

New Final Regulations Revise Rules on the Application of Section 163(j) to CFCs

McDermott Will & Emery on

As amended by the Tax Cuts and Jobs Act (TCJA), section 163(j) of the Internal Revenue Code (the Code) provides that a taxpayer’s interest expense is deductible only to the extent of the sum of: (i) the taxpayer’s interest...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

McDermott Will & Emery

[Webinar] Virtual Tax Forum | GILTI and Subpart F High Tax Exception Regulations: Practical Aspects and Implications (New Guidance...

McDermott Will & Emery on

The final and proposed regulations under sections 951A and 954 of the US Internal Revenue Code contain certain rules that may present planning opportunities—or possibly onerous results—depending on a taxpayer’s specific fact...more

Eversheds Sutherland (US) LLP

High time: Final and proposed regulations rework high-tax rule for GILTI and subpart F

Eversheds Sutherland (US) LLP on

Recently released final regulations provide some relief to taxpayers that are subject to high foreign taxes on their global intangible low-taxed income (GILTI), but whether the GILTI high-tax exclusion is beneficial to any...more

McDermott Will & Emery

Elective GILTI Exclusion for High-Taxed GILTI

McDermott Will & Emery on

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

McDermott Will & Emery

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

McDermott Will & Emery on

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

McDermott Will & Emery

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

McDermott Will & Emery on

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

Holland & Knight LLP

Tax Court Upholds Application of Subpart F Manufacturing Branch Rule

Holland & Knight LLP on

A U.S. shareholder of a foreign corporation generally is not subject to U.S. federal income tax on the income of the foreign corporation until the shareholder receives an actual distribution from the corporation. However,...more

Brownstein Hyatt Farber Schreck

Taxation & Representation - February 2020

Brownstein Hyatt Farber Schreck on

TAX TIDBIT - New National Taxpayer Advocate. The Internal Revenue Service (IRS) announced that a new National Taxpayer Advocate will likely be in place by April. According to an internal memo sent by IRS Commissioner...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

McDermott Will & Emery

Treasury and the IRS Release Final Foreign Tax Credit Regulations

McDermott Will & Emery on

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

62 Results
 / 
View per page
Page: of 3
Next »

"My best business intelligence, in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:
Sign up Log in
*By using the service, you signify your acceptance of JD Supra's Privacy Policy.
- hide
- hide