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.
International Tax
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.
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 regs. and proposed regs. issued under Secs. 245A and 954
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 TJCA.
Blockchain technology firms’ transfer-pricing issues
This article presents some of the transfer-pricing considerations that blockchain companies must address as they grow and expand across borders.
FBAR deadline extended to Oct. 31 after confusion
After a misworded posting caused confusion about the 2020 deadline to file FBARs (i.e., FinCEN Form 114, Report of Foreign Bank and Financial Accounts (FBAR)), Treasury’s Financial Crimes Enforcement Network has extended the deadline to Oct. 31.
FinCEN pulls announcement of extended FBAR deadline
Treasury’s Financial Crimes Enforcement Network briefly announced, but then rescinded, an extension of this year’s deadline to e-file FinCEN Form 114, Report of Foreign Bank and Financial Accounts (FBAR).
Rules govern withholding on transfers of partnership interests and ECI
The IRS finalized proposed regulations on withholding from transfers of partnership interests to foreign persons and the definition of effectively connected income for those purposes.
IRS issues more rules on GILTI tax
The IRS issued final regulations under the 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.
Foreign income taxes deemed paid and the PTEP rules
Treasury and the IRS temporary regulations include rules for determining foreign income taxes deemed paid under Sec. 960, which pertains to the “deemed paid” foreign tax credit.
Foreign tax credit allocation and apportionment rules finalized
The IRS issued final and proposed regulations covering a wide variety of issues involving deductions and credits for foreign taxes.
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.
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.
