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.
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
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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.