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Topic: International Tax

Not GILTI? Treasury Issues Final Regulations for Global Intangible Low-Tax Income High-Tax Exclusion
By Nick Zoyhofski, CPA on August 10, 2020

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...

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IRS Proposes Form 1065 Schedule K-2 and K-3 to Improve International Reports for Partnerships

Intention: 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...

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IRS Guidance Explains What’s GILTI; Less Clear on What’s Not
By Susan Steblein on November 20, 2018

IRS 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...

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Do You Need to Include the Sec. 965 Transition Tax on Your April 17, 2018 Tax Return or Extension?
By Cara Rossi on July 23, 2018

Use 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,

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Determine if You’re GILTI Using this Calculator
By Susan Steblein on April 24, 2018

A 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...

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Transfer Pricing Guidance - Base Erosion and Profit Shifting Restrictions
By Mike Mistretta & Sarah Glajch on April 23, 2018

Overview 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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