Repatriation Tax, GILTI & BEAT

Topics

February 1, 2021

GILTI and Subpart F treatment of distributions of appreciated property

Under the Subpart F regime, income subject to the regime is initially defined by what it includes, while under the GILTI regime, income subject to the regime is initially defined by what it excludes. This article discusses the application of these different approaches in the context of nonliquidating distributions from a controlled foreign corporation to a U.S. shareholder.

January 1, 2021

Treasury and IRS finalize DRD anti-abuse regulations with few changes

Treasury and the IRS released final regulations providing anti-abuse rules for extraordinary dispositions of assets and extraordinary reductions of dividends.

January 1, 2021

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.

November 23, 2020

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.

November 1, 2020

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.

November 1, 2020