The U.S. Congress has enacted the One Big Beautiful Bill Act (OBBB), formally renamed "An Act to provide for reconciliation pursuant to title II of H. Con. Res. 14." President Donald Trump signed the legislation into law on...more
7/21/2025
/ Base Erosion and Anti-Abuse Tax (BEAT) ,
Controlled Foreign Corporations ,
Excise Tax ,
Foreign Derived Intangible Income (FDII) ,
Foreign Tax Credits ,
G7 ,
GILTI tax ,
International Remittance Transfers ,
International Tax Issues ,
Multinationals ,
Tax Cuts and Jobs Act ,
Tax Exemptions ,
Tax Incentives ,
Tax Legislation ,
Tax Reform
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
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
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
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
A U.S. shareholder of a foreign corporation generally is not subject to U.S. federal income tax on the income of the foreign corporation until the shareholder receives an actual distribution from the corporation. However,...more
Highlights -
• In an unanticipated development, the U.S. Department of the Treasury (Treasury) and Internal Revenue Service (IRS) recently issued regulations (New Guidance) that significantly modifies the taxation of U.S....more
7/15/2019
/ Controlled Foreign Corporations ,
Domestic Partnership ,
GILTI tax ,
Income Taxes ,
IRS ,
Limited Liability Company (LLC) ,
Minority Shareholders ,
New Guidance ,
New Regulations ,
Pass-Through Entities ,
Passive Foreign Investment Company ,
S-Corporation ,
Stocks ,
Subpart F ,
U.S. Treasury