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.
International Tax
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.
Move to territorial system may not discourage profit shifting
The shift to a territorial system was designed to help dissuade U.S. companies from moving profits overseas, but it may make the practice more rewarding instead.
Proposed rules would exempt corporate US shareholders from Sec. 956
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.
Offshore account holders should beware: The IRS is still coming
Taxpayers with undisclosed offshore accounts would be wise to take advantage of the lesser known IRS voluntary disclosure process.
Association addresses digital economy tax issues
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.
Tax reform: Individual taxpayers and the Sec. 962 election
The new "repatriation tax" under the TCJA may cause individual partners and shareholders of flowthrough entities to obtain a deferred tax rate benefit by making this election.
IRS issues Sec. 965 transition tax regs.
The IRS issued proposed regulations on the Sec. 965 transition tax that requires U.S. shareholders of deferred foreign income corporations to pay tax on post-1986 deferred income.
Different SALT flavors of mandatory deemed repatriation under Sec. 965
This item discusses new trends in states’ conformity with or decoupling from Sec. 965.
