GILTI tax, Foreign Derived Intangible Income (FDII), Foreign Corporations

One Big Beautiful Bill Introduces Major Changes to Federal Tax Law

Latham & Watkins LLP on 7/22/2025

On July 4, 2025, President Trump signed the One Big Beautiful Bill Act (the OBBB) into law, making permanent the reduced individual tax rates and brackets established by the Tax Cuts and Jobs Act of 2017 and modifying a...more

Impact of House Ways and Means Tax Proposals for International Operations

Bowditch & Dewey on 10/4/2021

In this final blog post on the House Ways and Means Tax Bill, we address the international tax proposals in the Bill, JCX-43-21. The international tax proposals are fewer in number than the domestic and transfer tax...more

Biden Administration's Made in America Tax Plan: Interaction with OECD Inclusive Framework

Holland & Knight LLP on 4/16/2021

The American Jobs Plan is a proposal to increase investment in infrastructure, the production of clean energy, the care economy and other priorities. The Made in America Tax Plan (Tax Plan) is the vehicle to pay for the...more

Proposed FDII Regulations under Section 250

Proskauer - Tax Talks on 4/23/2019

On March 4, 2019, the Internal Revenue Service (the “IRS”) and the Department of the Treasury (the “Treasury”) released proposed regulations (the “Proposed Regulations”) regarding the deduction for “foreign-derived intangible...more

The Last Piece of the Puzzle - the Section 250 Proposed Regulations

Eversheds Sutherland (US) LLP on 3/13/2019

Public Law 115-97 (the Tax Cuts and Jobs Act) added a new foreign income inclusion rule for global intangible low-taxed income (GILTI) under section 951A. The Tax Cuts and Jobs Act also added section 250, which permits...more

U.S. Tax Reform: Impacts and Opportunities for Mexican Businesses, Part 1 - A General Overview on Issues That U.S. and Mexican...

Holland & Knight LLP on 7/23/2018

• The Tax Cuts and Jobs Act (Tax Act), signed into law on Dec. 22, 2017, made significant changes to the manner in which U.S. corporate and individual taxpayers are taxed on income from international operations. • The Tax...more

Governor Baker Proposes Tax Changes to Address Federal Reform, Wayfair Case

Sullivan & Worcester on 6/14/2018

In a supplemental appropriations bill for FY 2018, Governor Charlie Baker has proposed amendments to Massachusetts tax law that would deal with the two "hottest" issues on the state and local tax front nationally in the...more

New York State Responds to Federal Tax Reform

Skadden, Arps, Slate, Meagher & Flom LLP on 4/10/2018

On March 30, 2018, the New York Legislature passed the 2018–2019 Budget Bill (SB. 7509-C/A 9509-C) (Budget Bill), which addresses several provisions of the newly enacted Tax Cuts and Jobs Act (P.L. 115-97) (TCJA) and...more

GILTI tax › Foreign Derived Intangible Income (FDII) › Foreign Corporations

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