On July 20, 2020, the US Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued proposed regulations (REG-127732-19) (the 2020 Proposed Regulations) that would conform the historic Subpart F...more
8/7/2020
/ CFC ,
Controlled Foreign Corporations ,
Corporate Taxes ,
Federal Trade Commission (FTC) ,
GAAP ,
GILTI tax ,
IFRS ,
Income Taxes ,
IRS ,
New Rules ,
Proposed Regulation ,
Shareholders ,
Subpart F ,
Tax Cuts and Jobs Act ,
Tax Rates ,
U.S. Treasury
A domestic corporation's royalty income derived in connection with business conducted outside the United States generally is eligible for the reduced 13.125 percent effective tax rate on foreign derived intangible income...more
The 2017 tax reform legislation added section 250 to the Internal Revenue Code, effectively creating a new preferential tax rate for income derived by domestic corporations from serving foreign markets. The new deduction is...more