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Section 951

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

Questioning Old Regulations

August 1, 2019 By Jasper L. (Jack) Cummings, Jr.

In response to the Third Circuit's SIH Partners v. Commissioner ruling, our Federal Tax Group reflects on the decision and suggests taking a second look at old Treasury regulations that might not survive judicial scrutiny.

The court worked hard to save Section 956
How much deference will a court give Treasury?
For example: Section 951

Read the full advisory here. [...]Read more

Filed Under: Federal Tax Advisory Tagged With: Section 951, Section 956, Subpart F, Third Circuit, Treasury

Plot Twist – Proposed Regulations Mean Section 956 Did Not Actually Survive Tax Reform Intact

November 15, 2018 By Jasper L. (Jack) Cummings, Jr., Scott Harty and Daniel Reach

Our International Tax Group takes stock of new proposed regulations that try to keep Section 956 relevant despite the Tax Cuts and Jobs Act.

Many were left scratching their heads
“A result directly at odds with the manifest purpose of Section 956”
Impact of the proposed regulations

Read the full advisory here. [...]Read more

Filed Under: International Tax Advisory Tagged With: CFC, IRS, Revenue Act of 1962, Section 951, Section 956, Tax Cuts and Jobs Act, tax reform, TCJA, Treasury

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