Final regs. govern CFC downward attribution
The IRS issued final regulations on the downward attribution rules of controlled foreign corporations, whose treatment had been changed by the law known as the Tax Cuts and Jobs Act.
International Tax
Additional BEAT regs. finalized
The IRS issued final regulations on the base-erosion and anti-abuse tax, which was created by the Tax Cuts and Jobs Act to deter attempts to shift profits to foreign jurisdictions.
Regulations coming on S corporations with accumulated E&P and GILTI
The IRS announced that it will issue regulations to allow S corporations with accumulated earnings and profits to elect to have global intangible low-taxed income inclusions increase the S corporation’s accumulated adjustments account.
Final regs. address new dividends received deduction and reporting rules
The IRS finalized regulations and withdrew temporary regulations on the Sec. 245A dividend rules, as well as Sec. 954 and the reporting requirements for those new rules under Sec. 6038, which were all amended by the law known as the Tax Cuts and Jobs Act.
Export tax incentives after the Tax Cuts and Jobs Act
The TCJA introduced a new export tax incentive — the Sec. 250 deduction for foreign-derived intangible income — that is available only to domestic C corporations.
GILTI rules address income subject to high foreign tax rate
The IRS issued final regulations under the global intangible low-taxed income (GILTI) rules on the treatment of income subject to a high rate of foreign tax. At the same time, the IRS issued proposed rules conforming the GILTI high-tax exception rules with the Subpart F high-tax exception.
FDII and GILTI regulations finalized
The IRS issued final regs. on the foreign-derived intangible income deduction and the global intangible low-taxed income provisions enacted by the TCJA.
Taxpayer avoids Sec. 954(d)(1) Scylla but not Sec. 954(d)(2) Charybdis
A US company’s income earned by a Luxembourg subsidiary from sales of products made by a Mexican branch of the subsidiary is taxable as foreign base company sales income under Subpart F.
Reducing GILTI liability using CFC accounting method change procedures
Methods of accounting may be an effective tool in tax planning for GILTI; however, method change procedures for CFCs differ from procedures for domestic taxpayers.
Taxpayer’s failure to report foreign accounts was willful
Willful FBAR penalties upheld because taxpayer exhibited willful blindness of or recklessly violated the FBAR reporting requirements.
Withholding and reporting of partnership distributions to non-US partners
The mechanics of the withholding regime seem straightforward, but they can be difficult for certain tiered partnership structures.
Foreign trust reporting: Beware of late-filing penalties
Late-filing penalties for foreign trust filings can be devastating to clients and a significant challenge to CPAs trying to explain or eliminate them.
Foreign pension plans and the US-UK tax treaty
Whether contributions, earnings, and distributions are includible in the taxpayer’s income depends on the type of foreign pension plan and whether a tax treaty exempts an event that is otherwise taxable.
Puerto Rico: A permanent tax deferral in a GILTI world?
Under the right set of circumstances, there may be a significant opportunity for tax savings in Puerto Rico.
Section 301 China tariffs: Where things stand
This item discusses the back-and-forth negotiations and tit-for-tat tariff increases leading to significant economic tensions between the U.S. and China.
Relief for tax residency impacts of COVID-19 travel disruptions
Individuals and businesses can avoid having their prolonged stay in a country affect their tax residence if their cross-border travel was disrupted by the COVID-19 pandemic, under limited relief the IRS announced in two revenue procedures and FAQs.
Individual election to be taxed at corporate rates
Until now, shareholders had rarely invoked the Sec. 962 election to be taxed at corporate rates, and, as a result, most states have provided no specific guidance on how to treat a Sec. 962 election for state income tax purposes.
Final regulations address covered assets acquisition rules
The IRS issued final regulations that govern covered asset acquisitions, which are used to increase foreign tax credits.
Foreign gifts: A common example of undisclosed foreign transactions
Here’s what may happen when a foreign gift has not been disclosed.
Country-by-country reporting: Considerations facing US multinationals
As the OECD member states plan to review the CbC framework in 2020, this discussion highlights several common issues large U.S. MNEs may face.
