Repatriation Tax, GILTI & BEAT
The IRS issued final rules on the Sec. 245A extraordinary disposition rule and the Sec. 951A disqualified basis and disqualified payment rules, as well as reporting requirements to facilitate the rules.
This item discusses how new rules would affect taxpayers’ ability to claim FTCs for foreign income taxes that are offset with refundable tax credits in a foreign jurisdiction.
Under the Subpart F regime, income subject to the regime is initially defined by what it includes, while under the GILTI regime, income subject to the regime is initially defined by what it excludes. This article discusses the application of these different approaches in the context of nonliquidating distributions from a controlled foreign corporation to a U.S. shareholder.
IRS Notice 2020-69 provided a new entity election that allows an S corporation to compute the deemed inclusions at the entity level, as opposed to at the shareholder level. This item provides background on the new election, illustrates its effects, and highlights opportunities and traps to consider when contemplating the election.
This discussion summarizes proposed regulations that would coordinate two sets of rules that apply
to extraordinary dispositions and disqualified transfers of property.
Treasury and the IRS released final regulations providing anti-abuse rules for extraordinary dispositions of assets and extraordinary reductions of dividends.
The IRS issued final rules on the Sec. 245A extraordinary disposition rule and the Sec. 951A disqualified basis and disqualified payment rules, as well as reporting requirements to facilitate the rules.
The IRS issued final regulations on the base-erosion and anti-abuse tax, which was created by the TCJA to deter attempts to shift profits to foreign jurisdictions.
The final regulations on the GILTI high-tax exclusion mostly follow the 2019 proposed regulations but with some modifications.
