The Global Intangible Low-Taxed Income (GILTI) provisions were enacted as part of the 2017 Tax Cuts and Jobs Act (TCJA). Under the GILTI provisions, a U.S. shareholder essentially is taxed on the active earnings of a...more
A U.S. shareholder of a foreign corporation generally is not subject to U.S. federal income tax on the income of the foreign corporation until the shareholder receives an actual distribution from the corporation. However,...more
• The U.S. Department of the Treasury has released proposed regulations dealing with the application of the recent U.S. tax reform to U.S. shareholders of a "controlled foreign corporation" (CFC).
• A foreign corporation...more
3/6/2019
/ Controlled Foreign Corporations ,
Corporate Taxes ,
Foreign Earned Income ,
Foreign Tax Credits ,
GILTI tax ,
Income Taxes ,
Proposed Regulation ,
Shareholders ,
Stock Ownership ,
Tax Credits ,
Tax Cuts and Jobs Act ,
Tax Planning ,
U.S. Treasury
• The Internal Revenue Service has issued a proposed regulation that in many cases should eliminate the detrimental U.S. tax consequences to a U.S. corporation under Section 956 of the Internal Revenue Code when the...more
11/9/2018
/ Controlled Foreign Corporations ,
Corporate Financing ,
Dividends ,
IRS ,
Limited Liability Company (LLC) ,
Partnerships ,
Proposed Regulation ,
Section 956 ,
Shareholders ,
Subsidiaries ,
Tax Cuts and Jobs Act
The Protecting Americans from Tax Hikes Act of 2015 (PATH Act) was signed into law on Dec. 18, 2015, as part of the Consolidated Appropriations Act, 2016. The PATH Act alters the regime for taxing foreign persons holding U.S....more