Final Regulations under §951A (GILTI) and §954: Allows taxpayers to exclude from gross tested income, gross income of a tested unit subject to foreign income tax at an effective rate that...
Continue ReadingIntention: more closely align info partnerships report to partners with forms that partners use The IRS is in the process of redesigning the U.S. tax return for partnerships in order to...
Continue ReadingIRS Proposes Rules on Calculation of GILTI The IRS has released guidance on the taxation of “global intangible low-taxed income” (GILTI) reported by US shareholders of corporations outside...
Continue ReadingUse this handy guide from the international tax experts at Freed Maxick to pinpoint your Sec 965 compliance requirements re: foreign earnings Included in the Tax Cuts and Jobs Act of 2017,
Continue ReadingA Good First Step On Your Journey To GILTI Compliance Or Avoidance In a blog post I wrote a few weeks ago, I talked about two...
Continue ReadingOverview of the Three Tiered BEPS Action Plan Requirements As enterprises continue to expand operations across borders, Base Erosion and Profit Shifting (BEPS) has become a prioritized...
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