Is your inventory sales income U.S. or foreign source? Well, it depends. In case you missed it, our International Tax Group explores the various sourcing rules the IRS has proposed to sort out possible inconsistencies and overlaps caused by the Tax Cuts and Jobs Act.
Place of production now determines source for sales of produced inventory
Coordinating Section 863(b) and Section 865 for sales through an office
The overlap of Section 865(e)(2) and Section 864(c)(4)(B)(iii) for certain “nonresidents”
Read the full advisory here. [...]Read more
Missing piece to CARES? Our Federal Tax Group excavates this missing piece and investigates how it would have restored what was repealed by the Tax Cuts and Jobs Act.
Restoration of Section 958(b)(4)
New Section 951B
A newly minted controlled foreign corporation (CFC) regime
Ready full advisory here. [...]Read more