Guidance proposed on FDII and GILTI deductions
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.
International Tax
IRS proposes new foreign tax credit regulations
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.
Guidance on the new base-erosion and anti-abuse tax released
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.
Missing links: Tax reform’s impact on the value chain
In a changing landscape, U.S. C corporation multinationals should consider reevaluating their value chain.
Unintended consequences: How a drafting glitch turned Sec. 958 upside down
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.
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.
Is your client the subject of an FBAR examination?
This article discusses a few key things practitioners should know about FBAR cases.
Final regulations govern Sec. 965 transition tax
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.
IRS issues guidance on REITs’ treatment of certain foreign income inclusions
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).
GILTI regime guidance answers many questions
This article discusses the GILTI regime and the rules in proposed regulations and some of the most notable implications.
US-Mexico-Canada Agreement to replace NAFTA
The proposed USMCA covers new areas such as labor, the environment, anti-corruption, and regulatory policy, among others
OECD releases additional guidance on country-by-country reporting and updated exchange relationships
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.
U.S. corporate shareholders would no longer be subject to income inclusion rules
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.
Proposed GILTI regs. provide useful guidance on certain consolidated return issues
The proposed regulations effectively treat a consolidated group as a single entity for purposes of determining the sharing of tested loss.
Tax rules for the digital economy should be determined globally
The Association of International Certified Professional Accountants released a policy paper urging global solutions to the tax treatment of transactions in the digital economy, emphasizing its own Guiding Principles of Good Tax Policy.
IRS announces changes to Sec. 965 transition tax rules
Treasury and the IRS announced certain amendments to the rules included in the proposed regulations under Sec. 965.
Proposed regs. govern tax on base-erosion payments
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.
Global intangible low-taxed income rules are issued in proposed form
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.
Proposed foreign tax credit regulations issued
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.
Avoiding a transfer-pricing audit: 3 best practices for multinationals
Effectively navigating transfer-pricing regulations may be less about avoiding taxes and more about making smart decisions.
