Foreign Subsidiaries

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.

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.

IRS issues proposed regs. for GILTI inclusions

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.

Tax Insider Articles

DEDUCTIONS

Business meal deductions after the TCJA

This article discusses the history of the deduction of business meal expenses and the new rules under the TCJA and the regulations and provides a framework for documenting and substantiating the deduction.

TAX RELIEF

Quirks spurred by COVID-19 tax relief

This article discusses some procedural and administrative quirks that have emerged with the new tax legislative, regulatory, and procedural guidance related to COVID-19.