International Tax

Topics

January 1, 2019

U.S. corporate shareholders would no longer be subject to income inclusion rules

The IRS issued proposed regulations providing that Sec. 956, which requires an income inclusion by U.S. shareholders of controlled foreign corporations (CFCs) that invest in U.S. property, should not apply to corporate shareholders.

January 1, 2019

OECD releases additional guidance on country-by-country reporting and updated exchange relationships

The OECD guidance aims to give greater certainty to tax administrations and multinational enterprise groups on the implementation and operation of BEPS Action 13 Country-by-Country Reporting.

January 1, 2019

GILTI regime guidance answers many questions

This article discusses the GILTI regime and the rules in proposed regulations and some of the most notable implications.

January 1, 2019

IRS issues guidance on REITs’ treatment of certain foreign income inclusions

Sec. 856(n)(1)(a) specifies that passive foreign
exchange gain (as defined in Sec. 856(n)(3)) for any tax year is not gross income for purposes
of Sec. 856(c)(2).

December 14, 2018

Proposed regs. govern tax on base-erosion payments

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.

December 1, 2018

Global intangible low-taxed income rules are issued in proposed form

The IRS issued proposed regulations implementing Sec. 951A’s global intangible low-taxed income provision, which requires a US shareholder of a controlled foreign corporation to include this income in the shareholder’s gross income.

November 29, 2018

Proposed foreign tax credit regulations issued

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.

November 1, 2018

Move to territorial system may not discourage profit shifting

The shift to a territorial system was designed to help dissuade U.S. companies from moving profits overseas, but it may make the practice more rewarding instead.

November 1, 2018

Avoiding a transfer-pricing audit: 3 best practices for multinationals

Effectively navigating transfer-pricing regulations may be less about avoiding taxes and more about making smart decisions.

October 31, 2018

Proposed rules would exempt corporate US shareholders from Sec. 956

October 25, 2018

Offshore account holders should beware: The IRS is still coming

Taxpayers with undisclosed offshore accounts would be wise to take advantage of the lesser known IRS voluntary disclosure process.

October 23, 2018

Association addresses digital economy tax issues

The Association of International Certified Professional Accountants released a policy paper urging global solutions to the tax treatment of transactions in the digital economy, emphasizing its own Guiding Principles of Good Tax Policy.

October 1, 2018

Tax reform: Individual taxpayers and the Sec. 962 election

The new “repatriation tax” under the TCJA may cause individual partners and shareholders of flowthrough entities to obtain a deferred tax rate benefit by making this election.

October 1, 2018

Reassessing the tax benefits of IC-DISCs

Due to TCJA tax rate differential changes, taxpayers may find that the tax benefits of using an IC-DISC
no longer outweigh the compliance and maintenance costs.

October 1, 2018

IRS issues Sec. 965 transition tax regs.

The IRS issued proposed regulations on the Sec. 965 transition tax that requires U.S. shareholders of deferred foreign income corporations to pay tax on post-1986 deferred income.

October 1, 2018

An old friend reconsidered: Post-TCJA Sec. 338(g) elections for foreign targets

the TCJA’s implementation of a hybrid territorial international tax regime mitigates the benefit of the election and may induce taxpayers to not make the election to avoid additional tax liability on the eventual sale of foreign target shares.

October 1, 2018