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Sourcing the Source of Inventory Sales – Final Regulations Under Section 863(b)

October 26, 2020 By April McLeod and Sam Kaywood

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)

Filed Under: International Tax Advisory Tagged With: Section 1.954-3(a)(4), Section 168(g)(2), Section 861(a)(6), Section 863(b), Section 863(b)(2), Section 865, Section 865(e)(2), Tax Cuts and Jobs Act, tax reform, TCJA, title passage

Crystal Ball Gazing for the Federal Estate and Gift Tax After 2020 – Should I Act Now?

September 18, 2020 By Jacob Kaplan and Margaret Scott

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?

Filed Under: Wealth Planning Alert Tagged With: Estate, Gift Tax, Tax Cuts and Jobs Act, TCJA

The BEAT Goes On and On – New Final BEAT Regulations

September 18, 2020 By Richard Slowinski and Stefanie Kavanagh

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

Filed Under: International Tax Advisory Tagged With: anti-abuse tax, Base Erosion and Anti-Abuse Tax, BEAT, IRS, REITs, RICs, S Corp, Section 59A, Treasury

Treasury’s High Wire Act – Final and Proposed Regulations on CFC High-Tax Exceptions

August 18, 2020 By Edward Tanenbaum and Heather Ripley

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

Filed Under: International Tax Advisory Tagged With: CARES Act, CFC, GILTI, high-tax exclusion, HTE, QBU, Section 267, Section 951, Section 954, Subpart F, tax reform, TCJA

Challenges With Escheatment of Tax-Deferred Retirement Assets, Part 2

August 3, 2020 By Matt Hedstrom and Kendall Houghton

Holders of tax-deferred retirement assets must weigh and balance significant owner-facing risks against a clear set of state-facing compliance requirements and risks. In this installment of “UP Ahead” for Tax Notes State, unclaimed property partners … [Continue reading] about Challenges With Escheatment of Tax-Deferred Retirement Assets, Part 2

Filed Under: Unclaimed Property Tagged With: ERISA, Escheat, IRA, IRS, required minimum distribution, RMD, Roth IRA, RUUPA, SECURE, Setting Every Community up for Returement Enhancement Act, tax deferred retirements, Tax Notes State, The Further Consolidated Appropriations Act, UP Ahead

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