The passive foreign investment company (“PFIC”) rules generally impose unfavorable tax treatment on certain U.S. shareholders of foreign corporations that generate excess passive income or hold excess passive assets. In...more
The final regulations addressing the GILTI high-tax exception retain the general approach of the proposed regulations with some simplifying changes.
Key Points:
..Taxpayers can elect on an annual basis whether to...more
Section 956 final regulations confirm those eligible for territorial dividend exemption can benefit from foreign guarantee and collateral support without incurring US tax.
On May 23, 2019, the US Treasury and Internal...more