International Tax

Topics

June 1, 2019

States’ treatment of GILTI and FDII: The good, the bad, and the ugly

Review the various approaches states use to account for the GILTI and FDII regimes introduced by the TCJA.

May 8, 2019

Proposed rules would govern withholding on transfers of partnership interests

The IRS issued proposed regulations on the operation of new Sec. 1446(f), which requires withholding on the transfer of a partnership interest described in Sec. 864(c)(8) (gain or loss of foreign persons from the sale or exchange of certain partnership interests).

May 1, 2019

Proposed Sec. 956 regulations: Planning and pitfalls

This discussion addresses the proposed changes to the operation of Sec. 956, potential planning opportunities under the proposed regulations, and certain outstanding issues.

May 1, 2019

New CFC group election: Possible benefits

The TCJA substantially modified Sec. 163(j) so that the business interest expense in a tax year is limited to the sum of the taxpayer’s business interest income, 30% of the taxpayer’s adjusted taxable income, and the taxpayer’s floor plan financing interest.

April 1, 2019

GILTI: A new age of global tax planning

Only after careful examination of GILTI can U.S. taxpayers assess whether the TCJA benefits or harms their foreign earnings.

April 1, 2019

IRS issues Q&A guidance on Sec. 965 transition tax issues for 2018 returns

The IRS issues guidance for application of overpayments or refunds for taxpayers that opt to pay the Sec. 965 transition tax in eight annual
installments.

April 1, 2019

International tax considerations for the blockchain industry

Delineating the international tax considerations for a blockchain enterprise, a new industry involving new technology with almost no regulatory guidance, can be difficult.

April 1, 2019

Sec. 965 transition tax regulations are finalized

The IRS finalized proposed regulations issued last August on the new transition tax, which generally taxes the accumulated post-1986 deferred foreign income of a corporation.

March 5, 2019

Guidance proposed on FDII and GILTI deductions

The IRS issued guidance on determining the amount of the deduction for foreign-derived intangible income (FDII) and global intangible low-taxed income (GILTI) under Sec. 250.

March 1, 2019

Guidance on the new base-erosion and anti-abuse tax released

The IRS issued proposed rules on the Sec.59A base-erosion anti-abuse tax (BEAT), one of a number of new international tax provisions added by the law known as the Tax Cuts and Jobs Act.

March 1, 2019

IRS proposes new foreign tax credit regulations

The IRS issued proposed regulations on the determination of the foreign tax credit after the changes in the law made by the Tax Cuts and Jobs Act.

February 1, 2019

Unintended consequences: How a drafting glitch turned Sec. 958 upside down

This item provides an overview of the Sec. 958 constructive ownership rules, explores the “glitch” and its consequences, and discusses planning options to mitigate the negative effects.

February 1, 2019

Missing links: Tax reform’s impact on the value chain

In a changing landscape, U.S. C corporation multinationals should consider reevaluating their value chain.

February 1, 2019

Considerations when computing tested income and tested loss of a CFC

This discussion focuses on the computation of tested income or loss and comments on the mechanics of the computation, clarifies common misconceptions, and uncovers snags that may catch unsuspecting practitioners who have little experience navigating the GILTI provision.

January 31, 2019