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.
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.
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.
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.
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.
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.
The IRS issued final regs. on the foreign-derived intangible income deduction and the global intangible low-taxed income provisions enacted by the TCJA.
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.
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.
Willful FBAR penalties upheld because taxpayer exhibited willful blindness of or recklessly violated the FBAR reporting requirements.
The mechanics of the withholding regime seem straightforward, but they can be difficult for certain tiered partnership structures.
Late-filing penalties for foreign trust filings can be devastating to clients and a significant challenge to CPAs trying to explain or eliminate them.
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.
Under the right set of circumstances, there may be a significant opportunity for tax savings in Puerto Rico.
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.
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.
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.
The IRS issued final regulations that govern covered asset acquisitions, which are used to increase foreign tax credits.
Here’s what may happen when a foreign gift has not been disclosed.
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.