The IRS issued final regulations on the Sec. 951A global low-taxed income inclusion and foreign tax credits, finalizing proposed rules issued in October and December 2018.
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International Tax
The Subpart F high-tax exception before and after tax reform
While the statutory language to the high-tax exception was unchanged by the TCJA, other amendments affect the determination of whether an item of income meets the high-tax exception.
Key cross-border compensation issues
The use of a loan to facilitate the restricted stock purchase may be considered the grant of an option rather than the grant of restricted stock.
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.
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).
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
Is your client the subject of an FBAR examination?
This article discusses a few key things practitioners should know about FBAR cases.
Final regulations govern Sec. 965 transition tax
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.
Proposed GILTI regs. provide useful guidance on certain consolidated return issues
The proposed regulations effectively treat a consolidated group as a single entity for purposes of determining the sharing of tested loss.
TAX PRACTICE MANAGEMENT
2025 tax software survey
AICPA members in tax practice assess how their return preparation software performed during tax season and offer insights into their procedures.
