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Vinson & Elkins LLP

Treasury Releases Long-Awaited Proposed Regulations on the Corporate Alternative Minimum Tax

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On September 12, 2024, the Department of the Treasury (the “Treasury”) and the Internal Revenue Service (the “IRS”) issued long-awaited proposed regulations (89 FR 75062) (the “Proposed Regulations”) on the application of the...more

Ballard Spahr LLP

IRS Introduces a Domestic Filing Exception to Schedules K-2 and K-3

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Background - The Internal Revenue Service (IRS) introduced Schedules K-2 and K-3 beginning with tax year 2021. Schedule K-2 (Partners’ Distributive Share Items−International) and Schedule K-3 (Partner’s Share of Income,...more

McDermott Will & Emery

Weekly IRS Roundup August 8 – 12, 2022

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Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of August 8, 2022...more

McDermott Will & Emery

Weekly IRS Roundup August 10 – August 14, 2020

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Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of August 10, 2020 – August 14, 2020... August 10, 2020: The IRS published corrections to a notice...more

Fenwick & West LLP

The New Foreign Tax Credit Proposed Regulations – An Executive Summary

Fenwick & West LLP on

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

McDermott Will & Emery

New Foreign Tax Credit Rules May Warrant Restructuring Foreign Branches

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The 2017 Tax Act added a separate foreign tax credit limitation category, or basket, for income earned in a foreign branch. As a result, certain US groups may be limited in their ability to use foreign income taxes paid or...more

McDermott Will & Emery

Deference Provided to Regulations When There’s a Drafting Error

The Tax Act created two new foreign tax credit limitation baskets – one for foreign branch income (new section 904(d)(1)(B)) and one for any amount includible in gross income under section 951A (i.e., GILTI) – however, it...more

Morgan Lewis

IRS Publishes Guidance for RICs that Receive Foreign Tax Credit Refunds

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IRS announces the issuance of new regulations that will provide relief for certain regulated investment companies that receive foreign tax refunds by either netting the refund against foreign taxes paid in the year of the...more

McGuireWoods LLP

Tax Policy Update

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NUMBER OF THE WEEK: 52 percent. The likelihood that tax reform will happen in 2017 or earlier, according to the tax experts that participated in the Tax Council (TTC) and Ernst & Young (EY) Tax Reform Business Barometer in...more

Bilzin Sumberg

Tax Planning for the Privatization of the Space Industry

Bilzin Sumberg on

The privatization of the space industry has seen dramatic growth in recent years, and it appears that more significant developments are on the horizon....more

Skadden, Arps, Slate, Meagher & Flom LLP

Proposals May Signal Direction of Future Tax Reform

After several years of hearings and forums intended to develop broad-based support for comprehensive tax reform, on February 26, 2014, House Ways and Means Committee Chairman David Camp (R-Mich.) released a draft tax reform...more

K&L Gates LLP

The Shadow Transfer Pricing Rules: Crediting Foreign Taxes

K&L Gates LLP on

At the end of the 2013, the IRS issued, in the form of a Chief Counsel Advice [1] (CCA 201349015), its view on the applicability of transfer pricing concepts to transactions involving disregarded entities (“DEs”) in the...more

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