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Hone Maxwell

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

Hone Maxwell on

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

Davies Ward Phillips & Vineberg LLP

Revised U.S. Tax Proposals Will Affect Foreign Investment

Davies Ward Phillips & Vineberg LLP on

The U.S. House Committee on Rules recently released an updated version of the Build Back Better Act (Act) to reflect the White House’s Build Back Better framework (Framework) announced on the same day (October 28, 2021). ...more

BakerHostetler

White House Adds Details to Its Far-Reaching 2021 Tax Reform Plans

BakerHostetler on

The White House today released The American Families Plan, which includes some new details regarding the Biden administration’s proposed 2021 tax reform. The tax changes expected to be enacted this year will be substantial...more

Proskauer - Tax Talks

The Made in America Tax Plan: The Biden Administration Outlines its Tax Reform Proposals

Proskauer - Tax Talks on

On March 31, 2021, the White House released a factsheet describing the “American Jobs Plan”, a $2.3 trillion proposal for infrastructure spending that also contains certain significant tax credits, and the “Made in America...more

Alston & Bird

Biden’s International Tax Proposals – No Longer a Long Shot After Democrats Win in Georgia

Alston & Bird on

What does a (barely) Democratic Senate mean for Biden’s tax plans? Our International Tax Group discusses the President-elect’s broad proposals and how they could change the cross-border tax landscape....more

Proskauer - Tax Talks

Tax Proposals of President-Elect Biden and Other Prominent Democrats

Proskauer - Tax Talks on

This blog summarizes some of the tax proposals of President-elect Joe Biden and other prominent Democrats. Biden’s Proposals - Increased Individual Tax Rate - Biden would increase the top marginal income tax rate...more

Jackson Walker

Tax Planning for a Biden Presidency

Jackson Walker on

This past November, we outlined selected tax law changes that President-elect Joe Biden has proposed, both in speaking engagements and on his campaign website, some or all of which could be enacted in 2021 or future years. ...more

Jackson Walker

Tax Planning for a Biden Presidency

Jackson Walker on

With Biden as the projected President-Elect (subject to pending federal litigation and the Electoral College vote), tax planning for late 2020, 2021, and beyond is top of mind for many businesses and individuals....more

Fenwick & West LLP

Treasury and IRS Release Final and Proposed Foreign Tax Credit Regulations

Fenwick & West LLP on

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

Holland & Knight LLP

Relief on the Way to U.S. Individuals Owning Stock in a "Controlled Foreign Corporation" - Treasury Department's Proposed...

Holland & Knight LLP on

• 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

Fenwick & West LLP

The New Foreign Tax Credit Proposed Regulations – An Executive Summary

Fenwick & West LLP on

Released on November 30, 2018, the foreign tax credit proposed regulations provide a comprehensive new framework for calculating the foreign tax credit in light of several changes made by the Tax Cuts and Jobs Act (TCJA or...more

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