COD income and cross-border considerations
This item provides an overview of the federal tax rules that apply to debt modifications and restructurings, with a primary focus on how U.S. corporate shareholders of CFCs are affected.
Income & Exclusions
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.
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.
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.
Puerto Rico: A permanent tax deferral in a GILTI world?
Under the right set of circumstances, there may be a significant opportunity for tax savings in Puerto Rico.
Individual election to be taxed at corporate rates
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.
Country-by-country reporting: Considerations facing US multinationals
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.
Crime doesn’t pay — and may be taxable under Subpart F
One potentially important component of Subpart F income under Sec. 952(a)(4) is illegal bribes, kickbacks, or other payments made by or on behalf of a CFC to a foreign government official, employee, or agent.
New US duties on certain EU and Chinese goods
This item discusses punitive tarriffs.
Proposed rules would govern digital content and cloud computing
The IRS proposed regulations to clarify how to classify transactions involving digital content and cloud computing.
Rules proposed for classifying cloud and digital content transactions
The Internal Revenue Service proposed regulations to clarify how to classify transactions involving digital content and cloud computing.
Foreign-derived intangible income guidance addresses many open questions
Sec. 250 allows domestic corporations a deduction for their “foreign-derived intangible income.” Proposed regulations that were issued earlier this year answer many outstanding questions regarding the calculation of this new deduction but also include documentation requirements that may prove onerous for some taxpayers.
Final rules govern GILTI, Subpart F income, and foreign tax credits
The IRS issued final regulations on the Sec. 951A global low-taxed income inclusion and foreign tax credits, finalizing proposed rules issued in October and December 2018.
The Subpart F high-tax exception before and after tax reform
While the statutory language to the high-tax exception was unchanged by the TCJA, other amendments affect the determination of whether an item of income meets the high-tax exception.
Proposed Sec. 956 regulations: Planning and pitfalls
This discussion addresses the proposed changes to the operation of Sec. 956, potential planning opportunities under the proposed regulations, and certain outstanding issues.
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.
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).
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.
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.
