On June 26, 2023, the Supreme Court of the United States agreed to hear a rare challenge under the Sixteenth Amendment and Tax Clauses to Section 965 of the tax code. In Moore v. United States, the justices will consider...more
The final and proposed regulations under sections 951A and 954 of the US Internal Revenue Code contain certain rules that may present planning opportunities—or possibly onerous results—depending on a taxpayer’s specific fact...more
9/3/2020
/ Continuing Legal Education ,
Controlled Foreign Corporations ,
Exceptions ,
Foreign Affiliates ,
Foreign Earned Income ,
GILTI tax ,
Income Taxes ,
Intangible Property ,
Internal Revenue Code (IRC) ,
IRS ,
New Guidance ,
New Regulations ,
Proposed Regulation ,
Subpart F ,
Tax Liability ,
Tax Planning ,
Tax Rates ,
Webinars
On July 23, 2020, the US Department of the Treasury and the Internal Revenue Service (IRS) published final regulations addressing the global intangible low-taxed income (GILTI) high-tax exclusion (85 FR 44620) (the “Final...more
8/10/2020
/ CFC ,
Federal Trade Commission (FTC) ,
Foreign Tax ,
GILTI tax ,
Income Taxes ,
IRS ,
Proposed Regulation ,
Record Retention ,
Shareholders ,
Subpart F ,
Tax Cuts and Jobs Act ,
U.S. Treasury
Following the 2017 Tax Act, a domestic corporate purchaser of stock in a controlled foreign corporation (CFC) generally will desire to make a section 338(g) election. A section 338(g) election provides a stepped-up basis in...more