Bruyea v. United States (Ct. Claims Dec. 5, 2024), is the latest in a series of cases concerning whether a U.S. double tax treaty, in this case Canada's, allows a foreign tax credit for Canadian income taxes against the 3.8%...more
1/2/2025
/ Canada ,
Court of Federal Claims ,
Double Taxation ,
Foreign Tax ,
Foreign Tax Credits ,
Income Taxes ,
Internal Revenue Code (IRC) ,
International Tax Issues ,
NIIT ,
Tax Liability ,
Tax Treaty
On December 2, 2019, Treasury and the IRS released final and proposed regulations on the foreign tax credit. As expected, the final regulations finalize the 2018 proposed regulations relating mainly to the Tax Cuts and Jobs...more
1/6/2020
/ Controlled Foreign Corporations ,
Corporate Taxes ,
Final Rules ,
Foreign Earned Income ,
Foreign Tax Credits ,
GILTI tax ,
Income Taxes ,
International Tax Issues ,
Proposed Regulation ,
Tax Credits ,
Tax Cuts and Jobs Act ,
Tax Planning ,
U.S. Treasury
The application of §1248 and §338(g) in the context of the purchase or sale of a controlled foreign corporation (CFC) has long been one of the most complex areas of the tax code. The recently enacted tax reform act — herein,...more
9/18/2018
/ Asset Management ,
C-Corporation ,
Controlled Foreign Corporations ,
Corporate Taxes ,
Federal Taxes ,
GILTI tax ,
Income Taxes ,
International Tax Issues ,
IRS ,
New Rules ,
Partnerships ,
Pass-Through Entities ,
Private Equity Firms ,
Shareholders ,
Stock Purchase Agreement ,
Stock Sale Agreements ,
Stocks ,
Tax Code ,
Tax Cuts and Jobs Act ,
Tax Deferral ,
Tax Planning ,
Tax Reform
Recent months have seen significant IRS and judicial developments affecting financial institutions and market participants, including new FATCA changes and proposed regulations on dividend equivalent payments under section...more