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Tax Planning › GILTI tax › Tax Liability

Hone Maxwell

Understanding the One Big Beautiful Bill Act: GILTI Becomes Net CFC Tested Income (NCTI)

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Overview: The One Big Beautiful Bill Act (OBBB) renamed Global Intangible Low-Taxed Income (GILTI) to Net CFC Tested Income (NCTI), focusing on income earned by Controlled Foreign Corporations (CFCs). While the name change is...more

Bilzin Sumberg

Key International Tax Changes From the One Big Beautiful Bill Act

Bilzin Sumberg on

On July 4th, 2025, President Trump signed into law the One Big Beautiful Bill Act (“OBBBA”). This alert expands upon our Firm’s prior alert and is intended to summarize the main tax law changes that may impact: (i) U.S....more

McDermott Will & Schulte

Treasury Finalizes DPL Rules, Extends Transitional DCL Relief for Pillar Two Taxes

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Since the proposed dual consolidated loss (DCL) and disregarded payment loss (DPL) rules were released in August 2024, taxpayers have been wondering whether these controversial regulations would be finalized before the end of...more

Kilpatrick

4 Key Takeaways | New York Tax Developments

Kilpatrick on

On January 16th, Kilpatrick tax partner Jeff Reed presented during a New Jersey Society of CPAs, Bergen County seminar. Jeff discussed recent New York tax developments....more

Cadwalader, Wickersham & Taft LLP

Proposed Treasury Regulations Would Disallow Technique to Reduce Subpart F and GILTI Inclusions

Cadwalader, Wickersham & Taft LLP on

On December 9, 2022, Treasury released proposed regulations that would prevent consolidated groups from engaging in certain related party transactions to reduce the group’s Subpart F and GILTI inclusions. Specifically,...more

Freeman Law

[Webinar] The Freeman Law International Tax Symposium - October 20th - 21st, 9:00 am - 5:00 pm CST

Freeman Law on

Join leading tax experts from across the globe, as we discuss tax trends that are reshaping international taxation - AN EXPERIENCE UNLIKE ANY OTHER - Find yourself on the cutting-edge of international tax law, with...more

Polsinelli

The Proposed Build Back Better Act Moves Forward After the House Passes a Revised Version of the Bill

Polsinelli on

Overview - Over the past year, several tax law changes have been proposed by the Biden administration and, in September 2021, draft legislative language was circulated, which set forth proposed changes to the Internal...more

Miller Nash LLP

Today in Tax: Spin-offs, Tax Elections, and Subpart F

Miller Nash LLP on

Regulations frequently change as Congress adopts new policies and the IRS issues new or revised regulations implementing those policy changes. Tax elections based on existing law cannot be revoked if later regulatory changes...more

Freeman Law

[Webinar] Freeman Law International Tax Symposium – General Attendee - November 18th - 19th, 8:00 am - 5:00 pm CST

Freeman Law on

Join leading tax experts from across the globe, as we discuss tax trends that are reshaping international taxation - An Experience Unlike Any Other - Find yourself on the cutting-edge of international tax law, with...more

McDermott Will & Schulte

[Webinar] Virtual Tax Forum | GILTI and Subpart F High Tax Exception Regulations: Practical Aspects and Implications (New Guidance...

McDermott Will & Schulte on

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

McDermott Will & Schulte

Weekly IRS Roundup September 30 – October 4, 2019

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Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of September 30 – October 4, 2019. September 30, 2019: The IRS published a draft of the tax year...more

Foodman CPAs & Advisors

What is new in a “nutshell” for FORM 1040 for TAX YEAR 2018

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For Tax Year 2018, Taxpayers will use the new and re-designed Form 1040. Although the IRS’s sentiment is that many Taxpayers will only need to file Form 1040 and none of the NEW NUMBERED SCHEDULES, there will be Taxpayers...more

Holland & Knight LLP

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

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• 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

McDermott Will & Schulte

The New Participation Exemption: An Opportunity to Convert Ordinary Dividends into Qualified Dividends

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The Tax Cuts and Jobs Act introduced an important new benefit to US corporations that own 10 percent or more of a foreign corporation. Specifically, a full participation exemption has been enacted that exempts certain foreign...more

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