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Income Taxes › Tax Rates › 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 -
Cadwalader, Wickersham & Taft LLP

Senate Passes Inflation Reduction Act

Cadwalader, Wickersham & Taft LLP on

Below is a summary of the tax provisions in the Inflation Reduction Act of 2022 (the “IRA”), as passed by the Senate, that are likely to be of most interest to U.S. corporate taxpayers, financial institutions, hedge funds,...more

Proskauer - Tax Talks

Senator Manchin Announces That He Will Not Support the Build Back Better Act – Where Things Stand Now

Proskauer - Tax Talks on

Yesterday, on December 19, 2021, Senator Joe Manchin (D., W.Va.) said that he opposes the Build Back Better Act, which effectively prevents its passage.  While there are no immediate prospects for the Build Back Better Act to...more

Davies Ward Phillips & Vineberg LLP

Revised U.S. Tax Proposals Will Affect Foreign Investment

Davies Ward Phillips & Vineberg LLP on

The U.S. House Committee on Rules recently released an updated version of the Build Back Better Act (Act) to reflect the White House’s Build Back Better framework (Framework) announced on the same day (October 28, 2021). ...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

Mintz - ML Strategies

House Democrats Weigh Major Tax Changes for Businesses, Funds, and Individuals

Mintz - ML Strategies on

In May 2021, President Biden’s administration released a $6 trillion budget proposal for the coming fiscal year (Budget), including $3.6 trillion of tax increases over 10 years and generous tax credits to incentivize clean...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

Cadwalader, Wickersham & Taft LLP

A Comparison of Recent Tax Proposals

Cadwalader, Wickersham & Taft LLP on

This chart compares the Biden Administration’s Fiscal Year 2022 Revenue Proposals (the Greenbook), to the tax proposals in the Build Back Better Act (BBBA) approved by the House Ways and Means Committee on September 15, 2021....more

McGuireWoods LLP

Build Back Better Act: House Ways and Means Committee Tax Proposals – Key Issues for Corporations, Passthrough Entities, and...

McGuireWoods LLP on

On Sept. 15, 2021, the Ways and Means Committee of the U.S. House of Representatives approved a proposed tax legislative package (the “W&M proposal”) to the Build Back Better Act reconciliation bill (the “Act”), which...more

Miles & Stockbridge P.C.

Tax Alert: The Implications of House Democrats’ Tax Proposal

Miles & Stockbridge P.C. on

Big tax changes are on the way! President Biden, the House, and the Senate all seem to have their own agenda, but the proposal introduced by the House Ways and Means Committee (the “Proposal”) is a good starting point for...more

Kelley Drye & Warren LLP

House Ways and Means Committee Proposes Tax Law Changes

Kelley Drye & Warren LLP on

On September 13, 2021, the House Ways and Means Committee released draft legislation advancing a series of tax proposals (the “Ways and Means Tax Proposals”). This Client Advisory discusses some of these proposals....more

Bilzin Sumberg

The Draft of the International Tax Overhaul: Where is Captain America?

Bilzin Sumberg on

On August 25, 2021, Senate Finance Committee Chair Ron Wyden, D-Ore., and fellow Senate Finance Committee Democrats Sherrod Brown of Ohio and Mark R. Warner of Virginia released draft legislation, and a related summary,...more

Cadwalader, Wickersham & Taft LLP

A Look at the Biden Administration’s Fiscal Year 2022 Revenue Proposals

Cadwalader, Wickersham & Taft LLP on

I. Introduction - On May 28, 2021, the Treasury Department released the Biden Administration’s Fiscal Year 2022 Revenue Proposals (the Greenbook). ...more

Cadwalader, Wickersham & Taft LLP

A Look at the Tax Provisions in Biden’s Infrastructure Plan

Cadwalader, Wickersham & Taft LLP on

The American Jobs Plan is a $2 trillion plan to repair and revitalize America’s infrastructure. The plan includes: $115 billion to repair bridges, highways, roads and other transit systems...more

BakerHostetler

White House Adds Details to Its Far-Reaching 2021 Tax Reform Plans

BakerHostetler on

The White House today released The American Families Plan, which includes some new details regarding the Biden administration’s proposed 2021 tax reform. The tax changes expected to be enacted this year will be substantial...more

Proskauer - Tax Talks

The Made in America Tax Plan: The Biden Administration Outlines its Tax Reform Proposals

Proskauer - Tax Talks on

On March 31, 2021, the White House released a factsheet describing the “American Jobs Plan”, a $2.3 trillion proposal for infrastructure spending that also contains certain significant tax credits, and the “Made in America...more

Proskauer - Tax Talks

Tax Proposals of President-Elect Biden and Other Prominent Democrats

Proskauer - Tax Talks on

This blog summarizes some of the tax proposals of President-elect Joe Biden and other prominent Democrats. Biden’s Proposals - Increased Individual Tax Rate - Biden would increase the top marginal income tax rate...more

Jackson Walker

Tax Planning for a Biden Presidency

Jackson Walker on

This past November, we outlined selected tax law changes that President-elect Joe Biden has proposed, both in speaking engagements and on his campaign website, some or all of which could be enacted in 2021 or future years. ...more

Jackson Walker

Tax Planning for a Biden Presidency

Jackson Walker on

With Biden as the projected President-Elect (subject to pending federal litigation and the Electoral College vote), tax planning for late 2020, 2021, and beyond is top of mind for many businesses and individuals....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

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

Proskauer - Tax Talks

Democratic Tax Policy Proposals - February 2020

Proskauer - Tax Talks on

Recently, several of the presidential candidates and other prominent Democrats have suggested a number of different tax policy proposals, including wealth taxes, mark-to-market taxation, a VAT, additional taxes, increased...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

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

Bilzin Sumberg

Feeling GILTI Enough to Make a Section 962 Election?

Bilzin Sumberg on

After the passage of Public Law No. 115-97, formerly known as the Tax Cuts and Jobs Act (the “Tax Reform Act”), U.S. individual shareholders of controlled foreign corporations (“CFCs”) were faced with a difficult decision. ...more

Bilzin Sumberg

La reducción en la tasa impositiva corporativa en EE. UU. tendrá un impacto significativo en la planificación saliente de...

Bilzin Sumberg on

La Ley de Reducción de Impuestos y Empleos (Tax Cuts and Jobs Act, TCJA) representa el conjunto de medidas de reforma fiscal más significativo que fue promulgado desde 1986. ...more

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