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GILTI

Biden’s International Tax Proposals – No Longer a Long Shot After Democrats Win in Georgia

January 15, 2021 By Scott Harty and April McLeod

What does a (barely) Democratic Senate mean for Biden’s tax plans? Our International Tax Group discusses the President-elect’s broad proposals and how they could change the cross-border tax landscape. Raising the corporate and capital gain tax ratesDoubling the GILTI tax rateTax credits for repatriating manufacturing jobs to the U.S. Read the full advisory here. [...]Read more

Filed Under: International Tax Advisory Tagged With: capital gains, corporate tax, Georgia run off, GILTI, repatriating manufacturing jobs, Senate

Treasury’s High Wire Act – Final and Proposed Regulations on CFC High-Tax Exceptions

August 18, 2020 By Edward Tanenbaum and Heather Ripley

Our International Tax Group examines the high-tax exclusion (HTE) in new final regulations under the global intangible low-taxed income (GILTI) regime and the potentially precarious side effects U.S. shareholders face in choosing whether to apply the HTE. The 2020 final regulations apply the GILTI HTE on a “tested unit” and “all or nothing” basisThe 2020 proposed regulations would conform the Subpart F HTE to the finalized GILTI HTE, creating a single unified HTE for both regimesThe decision whether to elect the GILTI HTE must balance implications under other TCJA provisions and possibly [...]Read more

Filed Under: International Tax Advisory Tagged With: CARES Act, CFC, GILTI, high-tax exclusion, HTE, QBU, Section 267, Section 951, Section 954, Subpart F, tax reform, TCJA

Final FDII Regulations Released

July 16, 2020 By Edward Tanenbaum, Richard Slowinski and Stefanie Kavanagh

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. [...]Read more

Filed Under: International Tax Advisory Tagged With: advertising, CFC, Controlled Foreign Corporations, digital sales, FDII, GILTI, IRS, REITs, RICs, Section 250

Proposed Treasury Regulations Clarify UBTI “Silo” Rule

May 20, 2020 By Clay Littlefield, Daniel Reach, George Abney and Mark Williamson

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 ActEffects on Subpart F, GILTI, and other rules For the full advisory, click here. [...]Read more

Filed Under: Uncategorized Tagged With: CARES Act, Controlled Entities, Deb-financed properties, GILTI, IRS, NAICS, NOLs, partnership, QPI, S Corp, Schedule K-1, Subpart F, TCJA, Treasury, UDFI

Risky Business – Allocating Losses When Your Supply Chain Is Disrupted

April 17, 2020 By Stefanie Kavanagh and Richard Slowinski

Should a subsidiary incur losses due to risks it assumed? Can a parent take on losses? Our International Tax Group investigates the nuances of regulations from U.S. and international agencies and offers actions multinational enterprises can take now to prepare for the tax implications of COVID-19-related disruptions.

Who bears and controls the risk?
Useful guidance from the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations
Actions to take now and in the future

Alston & Bird has formed a multidisciplinary task force to advise clients on the business [...]Read more

Filed Under: International Tax Advisory Tagged With: 017 OECD Transfer Pricing Guidelines, 17 OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations, BEAT, Code, covid-19, customs, FDII, foreign distributor, GILTI, MNEs, multinational enterprises, NOLs, OECD, OECD TPG, Section 162, Section 163(j), section 482, Subpart F, Transfer Pricing Guidelines, VAT

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