Taxpayers have been eagerly awaiting, and the US Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) have been promising to provide, rules addressing the previously taxed earnings and profits (PTEP)...more
Discover the latest global developments and planning opportunities to stay ahead of the curve at McDermott’s Tax Symposium 2024. Join us in Chicago for a full day of programming designed to equip corporate tax leaders with...more
5/2/2024
/ Acquisitions ,
Best Practices ,
Continuing Legal Education ,
Controlled Foreign Corporations ,
Corporate Taxes ,
Corporate Transparency Act ,
Cross-Border ,
Digital Advertising Tax ,
Digital Goods ,
Energy Tax Incentives ,
Events ,
Family Offices ,
Federal Taxes ,
Foreign Assets ,
Foreign Derived Intangible Income (FDII) ,
Foreign Tax Credits ,
Income Taxes ,
Internet Tax Freedom Act ,
IRS ,
Mergers ,
Multinationals ,
OECD ,
Passive Foreign Investment Company ,
Pillar 2 ,
Reorganizations ,
Research and Development ,
Tax Credits ,
Tax Legislation ,
Tax Liability ,
Tax Litigation ,
Tax Planning ,
Tax Reform ,
Tax Returns ,
Virtual Currency
On October 31, 2023, the US District Court for the District of Colorado, in Liberty Global, Inc. v. United States, applied the codified economic substance doctrine and held—on summary judgment—that Liberty Global, Inc. (LGI)...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, the US tax costs to a corporate US shareholder that sells stock in a controlled foreign corporation (CFC) are significantly reduced. Beginning in 2018, the amount of gain will be generally less...more