On his first day in office, among the numerous Executive Orders (EO) released, President Donald Trump announced the America First Trade Policy EO designed to prioritize American interests in international trade and tax and,...more
1/31/2025
/ America First Trade Policy ,
Corporate Taxes ,
Executive Orders ,
International Tax Issues ,
International Trade ,
OECD ,
Section 301 ,
Tariffs ,
Tax Reform ,
Trump Administration ,
U.S. Treasury ,
US Trade Policies
As promised, the U.S. Department of the Treasury (Treasury Department) and IRS on Dec. 27, 2022, issued guidance regarding the new corporate alternative minimum tax (CAMT) enacted as part of the Inflation Reduction Act (IRA)....more
Addressing the tax challenges arising from the digitalization of the economy has been a top priority of the Base Erosion Profit Shifting (BEPS) project of the Organization for Economic Cooperation and Development (OECD)/G-20...more
A previous Holland & Knight alert provided an overview of corporate and individual income tax increases as detailed in the U.S. Department of the Treasury May 2021 "Green Book." (See "Biden Administration's FY 2022 Budget and...more
6/11/2021
/ Biden Administration ,
Controlled Foreign Corporations ,
Corporate Taxes ,
Foreign Tax ,
Foreign Tax Credits ,
GILTI tax ,
Green Book ,
International Tax Issues ,
Multinationals ,
OECD ,
Tax Cuts and Jobs Act ,
Tax Rates ,
Tax Reform ,
U.S. Treasury
By way of background, the budget that the president submits to Congress contains estimates of federal government income and spending for the upcoming fiscal year and also recommends funding levels for the federal government....more
6/4/2021
/ Appropriations Bill ,
Biden Administration ,
Corporate Taxes ,
Federal Budget ,
Green Book ,
Internal Revenue Code (IRC) ,
IRS ,
OECD ,
Proposed Legislation ,
Tax Reform ,
U.S. Treasury
Internal Revenue Service (IRS) Commissioner Chuck Rettig on April 13, 2021, told a U.S. Senate panel that the tax gap in the U.S. may total $1 trillion per year. In his view, the increase from prior estimates is due, in part,...more
5/7/2021
/ Biden Administration ,
Congressional Committees ,
Congressional Investigations & Hearings ,
Corporate Taxes ,
Cryptocurrency ,
Income Taxes ,
IRS ,
Large Business & International Division (LB&I) ,
Offshore Funds ,
Proposed Legislation ,
Tax Audits ,
Tax Evasion ,
Tax Haven ,
Tax Loopholes ,
Tax Reform ,
Wealth Tax
The American Jobs Plan is a proposal to increase investment in infrastructure, the production of clean energy, the care economy and other priorities. The Made in America Tax Plan (Tax Plan) is the vehicle to pay for the...more
4/16/2021
/ Base Erosion and Anti-Abuse Tax (BEAT) ,
Base Erosion Tax ,
Biden Administration ,
Corporate Taxes ,
Foreign Corporations ,
Foreign Derived Intangible Income (FDII) ,
GILTI tax ,
Infrastructure ,
Inversion ,
Legislative Agendas ,
OECD ,
Tax Rates ,
Tax Reform
During the run-up to the November presidential election, then-candidate Joe Biden previewed his tax priorities to enact a more progressive tax code to roll back "giveaways" to wealthy individuals and corporations under the...more
4/9/2021
/ Biden Administration ,
Budget Reconciliation ,
Corporate Taxes ,
Federal Budget ,
Legislative Agendas ,
OECD ,
Parliamentary Procedure ,
Tax Code ,
Tax Cuts and Jobs Act ,
Tax Rates ,
Tax Reform
In 2017, the IRS Large Business & International Division (LB&I) announced a new audit strategy known as "campaigns" that focused on issue-based rather than entity-based examinations, and focusing on those issues that present...more
The Global Intangible Low-Taxed Income (GILTI) provisions were enacted as part of the 2017 Tax Cuts and Jobs Act (TCJA). Under the GILTI provisions, a U.S. shareholder essentially is taxed on the active earnings of a...more