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.
Repatriation Tax, GILTI & BEAT
Assessment statutes of limitation and the Sec. 965 transition tax
As the IRS focuses more attention on Sec. 965, it is vital that taxpayers with Sec. 965 tax liabilities and their advisers understand the potentially applicable periods of limitation on assessment.
Refundable credits and foreign tax credits
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.
IRS finalizes rules for 100% dividends-received deduction, GILTI
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.
GILTI and Subpart F treatment of distributions of appreciated property
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.
Bridging the gap: GILTI and AAA
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.
Reducing the threat of double taxation from GILTI gap period rules
This discussion summarizes proposed regulations that would coordinate two sets of rules that apply to extraordinary dispositions and disqualified transfers of property.
Treasury and IRS finalize DRD anti-abuse regulations with few changes
Treasury and the IRS released final regulations providing anti-abuse rules for extraordinary dispositions of assets and extraordinary reductions of dividends.
Final rules coordinate Sec. 245A and Sec. 951A
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.
Final regulations on GILTI high-tax exclusion
The final regulations on the GILTI high-tax exclusion mostly follow the 2019 proposed regulations but with some modifications.
Base-erosion and anti-abuse tax rules are finalized
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.
