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Subpart F Exceptions

McDermott Will & Emery

GILTI High-Tax Exclusion: An Additional Planning Tool for Noncorporate US Shareholders

McDermott Will & Emery on

An individual or trust US shareholder of a controlled foreign corporation (CFC) faces harsh treatment under the global intangible low-taxed income (GILTI) regime. These tax implications have forced these taxpayers to pursue...more

McDermott Will & Emery

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

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

Alston & Bird

Treasury’s High Wire Act – Final and Proposed Regulations on CFC High-Tax Exceptions

Alston & Bird on

Our International Tax Group examines the high-tax exclusion (HTE) in new final regulations under the global intangible low-taxed income (GILTI) regime and the potentially precarious side effects U.S. shareholders face in...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

Dorsey & Whitney LLP

U.S. Tax Implications of Offshore Migration of Intellectual Property

Dorsey & Whitney LLP on

Challenges of Transferring IP Offshore - What constitutes intellectual property (“IP”) has long been a contested issue in tax practice, but generally includes intangible assets as wide-ranging as patents, copyrights,...more

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