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GILTI tax › Tax Cuts and Jobs Act › Taxable Income

Ropes & Gray LLP

2025 Tax Legislation Update: One Big Beautiful Bill Act Narrowly Passes Senate

Ropes & Gray LLP on

The “One Big Beautiful Bill Act” (the “BBB”) was passed by the U.S. House of Representatives on May 22, 2025 (such version, the “House Bill”) as part of the Republican Congress’s reconciliation package. The BBB generally...more

Eversheds Sutherland (US) LLP

Rev. Proc. 2021-26 provides accounting method change procedures for CFCs seeking to use the alternative depreciation system

Eversheds Sutherland (US) LLP on

Recently released Revenue Procedure 2021-26 (the Revenue Procedure) provides taxpayers with guidance regarding accounting method changes made on behalf of foreign corporations. The Revenue Procedure: ..Allows controlled...more

McDermott Will & Schulte

New Final Regulations Revise Rules on the Application of Section 163(j) to CFCs

McDermott Will & Schulte on

As amended by the Tax Cuts and Jobs Act (TCJA), section 163(j) of the Internal Revenue Code (the Code) provides that a taxpayer’s interest expense is deductible only to the extent of the sum of: (i) the taxpayer’s interest...more

Eversheds Sutherland (US) LLP

New York bill introduced to exempt GILTI

Eversheds Sutherland (US) LLP on

On June 11, 2018, Senate Bill 8991 (the Bill) was introduced by New York Senate Majority Leader John Flanagan. The Bill would decouple from the federal treatment of Global Intangible Low-Taxed Income (GILTI). ...more

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