The Tax Cuts and Jobs Act of 2017 continues to reverberate even unto the end of 2020. Our International Tax Group discusses a letter ruling that may have been a harbinger of proposed regulations to address exceptions to Section 367(a) gain recognition in light of the TCJA’s repeal of Section 958(b)(4). The specter of foreign-to-U.S. downward attributionCurtailing collateral effects of the repeal of Section 958(b)(4)Proposed regulations formalize pre-TCJA approach in targeted Section 367(a) … [Continue reading] about Letter Ruling Conjures Ghost of Section 958(b)(4) Past
Sourcing the Source of Inventory Sales – Final Regulations Under Section 863(b)
Is inventory personal? Well, it depends. In case you missed it, our International Tax Group recently explored the finalized sourcing rules that decide whether inventory is U.S. or foreign source after changes wrought by the Tax Cuts and Jobs … [Continue reading] about Sourcing the Source of Inventory Sales – Final Regulations Under Section 863(b)
Crystal Ball Gazing for the Federal Estate and Gift Tax After 2020 – Should I Act Now?
Death and taxes may be certainties, but the fate of the estate and gift tax after this election is far from it. Our Wealth Planning Team asks the questions that need asking to help you decide how to plan for the future. How can you cut through the … [Continue reading] about Crystal Ball Gazing for the Federal Estate and Gift Tax After 2020 – Should I Act Now?
The BEAT Goes On and On – New Final BEAT Regulations
Our International Tax Group elaborates on the final regulations recently issued by the IRS and Treasury on the base erosion and anti-abuse tax (BEAT). Key changes from the regulations proposed in 2019Clarification on determining a taxpayer’s … [Continue reading] about The BEAT Goes On and On – New Final BEAT Regulations
Treasury’s High Wire Act – Final and Proposed Regulations on CFC High-Tax Exceptions
Our International Tax Group examines the high-tax exclusion (HTE) in new final regulations under the global intangible low-taxed income (GILTI) regime and the potentially precarious side effects U.S. shareholders face in choosing whether to apply the … [Continue reading] about Treasury’s High Wire Act – Final and Proposed Regulations on CFC High-Tax Exceptions