Tax developments -
Pillar 2’s viability: Perspectives from industry leaders -
In a prior edition of Tax Bytes, we explained how “some, including the Finance Ministers of Hungary and India, have questioned the viability...more
3/19/2025
/ Corporate Taxes ,
Double Taxation ,
EU ,
Foreign Investment ,
International Tax Issues ,
IRS ,
Proposed Rules ,
Tax Planning ,
Tax Reform ,
Trump Administration ,
U.S. Treasury
Tax developments -
Other countries’ response to United States position on the Global Tax Deal -
On Friday, President Trump issued a memo discussing his administration’s intent to defend US companies from unfair foreign...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 October 2, 2017, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued Notice 2017-57 (the Notice) announcing that Treasury and the IRS:
- Are considering changes to the final...more