International Tax
The IRS issued proposed regulations on the operation of new Sec. 1446(f), which requires withholding on the transfer of a partnership interest described in Sec. 864(c)(8) (gain or loss of foreign persons from the sale or exchange of certain partnership interests).
This discussion addresses the proposed changes to the operation of Sec. 956, potential planning opportunities under the proposed regulations, and certain outstanding issues.
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.
The IRS finalized proposed regulations issued last August on the new transition tax, which generally taxes the accumulated post-1986 deferred foreign income of a corporation.
The IRS issued guidance on determining the amount of the deduction for foreign-derived intangible income (FDII) and global intangible low-taxed income (GILTI) under Sec. 250.
The IRS issued proposed regulations on the determination of the foreign tax credit after the changes in the law made by the Tax Cuts and Jobs Act.
The IRS issued proposed rules on the Sec.59A base-erosion anti-abuse tax (BEAT), one of a number of new international tax provisions added by the law known as the Tax Cuts and Jobs Act.
In a changing landscape, U.S. C corporation multinationals should consider reevaluating their value chain.
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.
This article discusses a few key things practitioners should know about FBAR cases.
The IRS finalized proposed regulations issued last August on the new transition tax, which generally taxes the accumulated post-1986 deferred foreign income of a corporation.
Sec. 856(n)(1)(a) specifies that passive foreign
exchange gain (as defined in Sec. 856(n)(3)) for any tax year is not gross income for purposes
of Sec. 856(c)(2).
This article discusses the GILTI regime and the rules in proposed regulations and some of the most notable implications.
The proposed USMCA covers new areas such as labor, the environment, anti-corruption, and regulatory policy, among others
The OECD guidance aims to give greater certainty to tax administrations and multinational enterprise groups on the implementation and operation of BEPS Action 13 Country-by-Country Reporting.
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.
