Treasury and the IRS released final regulations providing anti-abuse rules for extraordinary dispositions of assets and extraordinary reductions of dividends.
Repatriation Tax, GILTI & BEAT
Reducing the threat of double taxation from GILTI gap period rules
This discussion summarizes proposed regulations that would coordinate two sets of rules that apply
to extraordinary dispositions and disqualified transfers of property.
Final rules coordinate Sec. 245A and Sec. 951A
The IRS issued final rules on the Sec. 245A extraordinary disposition rule and the Sec. 951A disqualified basis and disqualified payment rules, as well as reporting requirements to facilitate the rules.
Base-erosion and anti-abuse tax rules are finalized
The IRS issued final regulations on the base-erosion and anti-abuse tax, which was created by the TCJA to deter attempts to shift profits to foreign jurisdictions.
Final regulations on GILTI high-tax exclusion
The final regulations on the GILTI high-tax exclusion mostly follow the 2019 proposed regulations but with some modifications.
employee benefits & pensions
Profits interests: The most tax-efficient equity grant to employees
By granting them a profits interest, entities taxed as partnerships can reward employees with equity. Mistakes, however, could cause challenges from taxing authorities.