Tag Archives: CFC

GILTI Basis Adjustments

▪ Written by

Our Federal Tax Group explores how Treasury’s proposed regulations could have the global intangible low-taxed income (GILTI) regime operating in a way you might not expect.

Read the full advisory here.

State of Uncertainty: GILTI Considerations for Individuals

▪ Written by and
Our International Tax Group explores the hidden terrain for individuals found in the new tax on global intangible low-taxed income (GILTI). The Section 250 deduction The renewed importance of Section 962 Beware of the C-corp. lobster pot Read the full advisory here. [...]Read more

First Round of Proposed GILTI Regulations Avoids the Hard(er) Stuff

▪ Written by and
The IRS’s opening salvo of proposed regulations under the Tax Cuts and Jobs Act’s global intangible low-taxed income is as complex as you would think. Our International Tax Group cuts through the clutter to address the key takeaways: Computation of GILTI inclusion Anti-abuse rules GILTI guidance still to come Read the full advisory here.  [...]Read more

Foreign-Derived Intangible Income

▪ Written by
It’s probably the next-best part of the Tax Cuts and Jobs Act for multinationals. Our Federal Tax Group investigates the foreign-derived intangible income regime and how you can use it. What is an export? Getting the CFC involved Selling a service Read the full advisory here. [...]Read more

Killing the Killer B: The Treasury and IRS Issue a Sixth Set of Rules on Killer B Transactions

▪ Written by and

The Treasury looks to slay Killer B transactions with its newest rules. Our International Tax Group follows the trail of glitches in the regulation.

Read the full advisory here.