Nearly two years ago, in the wake of the Tax Cuts and Jobs Act, the IRS issued interim guidance on the unrelated business taxable income (UBTI) “silo” rules. Our International Tax Group examines recently released proposed Treasury Regulations that largely follow, and partially expand, that guidance.
- Special rules for investment activities, including “qualified partnership interests”
- Interactions with net operating loss rules, as modified by the TCJA and the CARES Act
- Effects on Subpart F, GILTI, and other rules
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