The U.S. Supreme Court (“SCOTUS”) has decided to hear a case (Moore v. U.S., No. 22-800 ) where individual taxpayers owned shares in a controlled foreign corporation (“CFC”) and were subject to the so-called “transition tax”...more
As you may be aware, the House Ways and Means Committee recently approved a multitrillion-dollar tax package (the “Proposal”) that has significant tax impact on both individuals and corporations. ...more
9/20/2021
/ Base Erosion and Anti-Abuse Tax (BEAT) ,
Biden Administration ,
Budget Reconciliation ,
Controlled Foreign Corporations ,
Corporate Taxes ,
Foreign Derived Intangible Income (FDII) ,
Foreign Tax Credits ,
GILTI tax ,
International Tax Issues ,
Legislative Agendas ,
Private Equity ,
Tax Reform ,
Ways and Means Committee
On August 25, 2021, Senate Finance Committee Chair Ron Wyden, D-Ore., and fellow Senate Finance Committee Democrats Sherrod Brown of Ohio and Mark R. Warner of Virginia released draft legislation, and a related summary,...more
9/1/2021
/ Biden Administration ,
Controlled Foreign Corporations ,
Corporate Taxes ,
GILTI tax ,
Income Taxes ,
International Tax Issues ,
Proposed Legislation ,
Tax Cuts and Jobs Act ,
Tax Planning ,
Tax Rates ,
Tax Reform