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
The Proposed Regulations allow existing debt and non-debt contracts that now reference LIBOR and other Interbank Offered Rates (IBORs) to transition toward alternative reference rates without triggering tax.
Key...more
10/23/2019
/ Benchmarks ,
Debt Instruments ,
Fair Market Value ,
Inter-Bank Offered Rates (IBORs) ,
Interest Rates ,
International Tax Issues ,
Libor ,
Proposed Regulation ,
Safe Harbors ,
Secured Overnight Funding Rate (SOFR) ,
U.S. Treasury
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
The proposed regulations provide rules for identifying which taxpayers are subject to the BEAT and for computing BEAT liability.
Key Points:
The base erosion and anti-abuse tax (BEAT) proposed...more
Proposed regulations under Section 163(j) governing business interest deduction limitations confirm prior guidance and expand the scope of its application in some important respects.
On November 26, 2018, the Treasury and...more
12/20/2018
/ C-Corporation ,
Controlled Foreign Corporations ,
Corporate Taxes ,
GILTI tax ,
Interest Payments ,
Internal Revenue Code (IRC) ,
IRS ,
Partnerships ,
Proposed Regulation ,
REIT ,
S-Corporation ,
Tax Cuts and Jobs Act ,
Tax Deductions ,
U.S. Treasury
But Holding Period and Other Requirements Add Complexity -
On October 31, 2018, the US Treasury and Internal Revenue Service issued proposed regulations (the Proposed Regulations) that would eliminate, in most...more