Welcome to this week’s edition of Tax Bytes. Our team of tax lawyers is actively monitoring for federal and international tax developments and issues of note. Each week we pull together the items we deem most important to...more
Recently released final regulations provide some relief to taxpayers that are subject to high foreign taxes on their global intangible low-taxed income (GILTI), but whether the GILTI high-tax exclusion is beneficial to any...more
Significant provisions of the 2020 Proposed Regulations addressing the application of section 163(j) to foreign corporations and their shareholders include:
..An election under which a controlled foreign corporation (CFC)...more
On July 28, 2020, Treasury and the IRS released highly anticipated final regulations under section 163(j) and related amended regulations under sections 382 and 383 (Final Regulations). This legal alert focuses on provisions...more
As COVID-19 continues to spread around the globe, companies and individuals are facing a diverse and challenging set of issues. These issues span a number of different contexts including tax, and measures are being considered...more
The Tax Cuts and Jobs Acts (TCJA) repealed § 958(b)(4) of the Code, which prevented downward attribution of stock ownership from a foreign person to a US person. That repeal has resulted in many foreign corporations being...more
10/14/2019
/ Controlled Foreign Corporations ,
Corporate Taxes ,
Domestic Corporations ,
Foreign Entities ,
GILTI tax ,
Internal Revenue Code (IRC) ,
IRS ,
Proposed Regulation ,
Repeal ,
Reporting Requirements ,
Revenue Procedures ,
Safe Harbors ,
Tax Cuts and Jobs Act ,
U.S. Treasury
On September 5, 2019, the Internal Revenue Service (Service) and the Department of Treasury (Treasury) issued proposed regulations for Section 451(c) of the Internal Revenue Code (Code). Section 451(c) was added to the Code...more
On September 5, 2019, the Internal Revenue Service (IRS) and the Department of Treasury (Treasury) issued proposed regulations under section 451(b) of the Internal Revenue Code (Code). The proposed regulations generally...more
Public Law 115-97 (the Tax Cuts and Jobs Act (TCJA)) added a new foreign income inclusion rule for global intangible low-taxed income (GILTI) under section 951A. On September 13, 2018, the Department of the Treasury...more
9/25/2018
/ Controlled Foreign Corporations ,
Corporate Taxes ,
Foreign Tax Credits ,
GILTI tax ,
Income Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
Partnerships ,
Proposed Regulation ,
Shareholders ,
Tax Cuts and Jobs Act ,
U.S. Treasury
On August 1, 2018, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued proposed regulations, which were published in the Federal Register on August 9, 2018 (Proposed Regulations),...more
On July 2, 2018, the Large Business and International (LB&I) Division of the Internal Revenue Service (IRS) announced five new compliance campaigns, including campaigns relating to virtual currency and the transition tax...more