Controlled Foreign Corporations
Talk about a summer beach read... The IRS’s final regulations for Section 250 deductions for FDII and GILTI are here for your light summer reading. Better yet, let our International Tax Group explain it all for you.
The Section 250 deduction generally applies to domestic C corporationsA more relaxed and flexible approach to documentation and substantiation requirementsClarification for the software industry on foreign use of digital sales and advertising
Read the full advisory here.
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Sales of CFCs Got Harder?
Our Federal Tax Group gives a glimpse into the brave new world of selling foreign assets and stock in the wake of the Tax Cuts and Jobs Act.
- Selling a U.S. sub versus selling a CFC
- GILTI as a new option over Subpart F
- Analyzing the options
Read the full advisory here.
State of Uncertainty: GILTI Considerations for Individuals
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
Tax Act: Vote and Value
Our Federal Tax Group explains the nuances tax reform brings to the definition of a U.S. shareholder, including a surprise for controlled foreign corporations.
- U.S. shareholders
- The vote or value definition
- Controlled foreign corporations
Click here to read the full advisory.