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Letter Ruling Conjures Ghost of Section 958(b)(4) Past

November 23, 2020 By Edward Tanenbaum and Heather Ripley

The Tax Cuts and Jobs Act of 2017 continues to reverberate even unto the end of 2020. Our International Tax Group discusses a letter ruling that may have been a harbinger of proposed regulations to address exceptions to Section 367(a) gain recognition in light of the TCJA’s repeal of Section 958(b)(4). The specter of foreign-to-U.S. downward attributionCurtailing collateral effects of the repeal of Section 958(b)(4)Proposed regulations formalize pre-TCJA approach in targeted Section 367(a) context Click here to read the full advisory. [...]Read more

Filed Under: International Tax Advisory Tagged With: IRS, Letter Ruling, Section 367(a), Section 958(b)(4), Tax Cuts and Jobs Act, tax reform, TCJA

Sourcing the Source of Inventory Sales – Final Regulations Under Section 863(b)

October 26, 2020 By April McLeod and Sam Kaywood

Is inventory personal? Well, it depends. In case you missed it, our International Tax Group recently explored the finalized sourcing rules that decide whether inventory is U.S. or foreign source after changes wrought by the Tax Cuts and Jobs Act. Different rules for inventory produced, rather than purchased, by the taxpayerBut what if foreign branches sell inventory produced in the U.S.?Special rules for property sold through a U.S. office maintained by a nonresident Read the full advisory here. [...]Read more

Filed Under: International Tax Advisory Tagged With: Section 1.954-3(a)(4), Section 168(g)(2), Section 861(a)(6), Section 863(b), Section 863(b)(2), Section 865, Section 865(e)(2), Tax Cuts and Jobs Act, tax reform, TCJA, title passage

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

What’s Your Source? Proposed Regulations on Sourcing Inventory Sales

April 2, 2020 By Edward Tanenbaum and Heather Ripley

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

Filed Under: International Tax Advisory, Tax Reform Tagged With: IRS, nonresidents, Section 863(b), Section 864(c)(4)(B)(iii, Section 865, Section 865(e)(2), Tax Cuts and Jobs Act, tax reform, TCJA

Downward Stock Attribution for CFC Purposes

April 2, 2020 By Jasper L. (Jack) Cummings, Jr.

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

Filed Under: Federal Tax Advisory, Tax Reform Tagged With: CARES Act, CFC, Gross Income of Foreign Controlled United States Shareholders, Section 2209, Section 951B, Senate bill, Tax Cuts and Jobs Act, tax reform, TCJA

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