CFCs
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.
Delineating the international tax considerations for a blockchain enterprise, a new industry involving new technology with almost no regulatory guidance, can be difficult.
Only after careful examination of GILTI can U.S. taxpayers assess whether the TCJA benefits or harms their foreign earnings.
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.
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.
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.
In a changing landscape, U.S. C corporation multinationals should consider reevaluating their value chain.
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.
This article discusses the GILTI regime and the rules in proposed regulations and some of the most notable implications.
The proposed regulations effectively treat a consolidated group as a single entity for purposes of determining the sharing of tested loss.
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.
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.
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.
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.
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.
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.
One new opportunity created by the TCJA is the foreign-derived intangible income deduction in Sec. 250(a).
This item discusses provisions of the TCJA that seek to curb the erosion of the U.S. tax base.
This item discusses uncertainties regarding the
consequences of a midyear distribution
of PTI by a CFC.
Determining how to “properly attribute” a foreign
income tax to an income inclusion is unclear, particularly with respect to Sec. 956 inclusions.
