Treasury’s High Wire Act – Final and Proposed Regulations on CFC High-Tax Exceptions
Final FDII Regulations Released
Downward Stock Attribution for CFC Purposes
Missing piece to CARES? Our Federal Tax Group excavates this missing piece and investigates how it would have restored what was repealed by the Tax Cuts and Jobs Act.
Restoration of Section 958(b)(4)
New Section 951B
A newly minted controlled foreign corporation (CFC) regime
Ready full advisory here. [...]Read more
From Obscurity to Spotlight: The Section 962 Election
In case you missed it's release right before the President's Day holiday weekend, our International Tax Group addressed an election under Section 962 available to individual U.S. shareholders of certain foreign corporations to be taxed as a C corporation, which before tax reform was a rarely utilized and often forgotten tool that has recently been thrust into the spotlight due to its potential benefits.
The rise in popularity of the Section 962 election
Smith v. Commissioner, an unfavorable ruling for U.S. shareholders receiving distributions of foreign earnings subject to a Section 962 [...]Read more