Tag Archives: Subpart F

From Obscurity to Spotlight: The Section 962 Election

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In case you missed it's release right before the President's Day holiday weekend, our International Tax Group addressed an election under Section 962 available to individual U.S. shareholders of certain foreign corporations to be taxed as a C corporation, which before tax reform was a rarely utilized and often forgotten tool that has recently been thrust into the spotlight due to its potential benefits. The rise in popularity of the Section 962 election Smith v. Commissioner, an unfavorable ruling for U.S. shareholders receiving distributions of foreign earnings subject to a Section 962 [...]Read more

Down the Rabbit Hole: Guidance Addressing Downward Attribution After Repeal of Section 958(b)(4)

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The IRS released Proposed Regulations and a Revenue Procedure addressing the Tax Cuts and Jobs Act’s repeal of Section 958(b)(4). Our International Tax Group explores how this guidance affects numerous provisions of the Code. Downward attribution beyond Subpart F, GILTI, and Section 965 Silence on the portfolio interest exemption Safe harbors and eased reporting requirements Read the full advisory here. [...]Read more

Questioning Old Regulations

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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

Sales of CFCs Got Harder?

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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

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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

International Tax Reform Is Here

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Our International Tax Group reveals how savvy and flexible taxpayers can optimize their tax position in the new landscape created by the Tax Cuts and Jobs Act. New territorial system and mandatory repatriation Anti-base erosion measures Changes to Subpart F and other provisions Click here to read the full advisory. [...]Read more