Discover the latest global developments and planning opportunities to stay ahead of the curve at McDermott’s Tax Symposium 2024. Join us in Chicago for a full day of programming designed to equip corporate tax leaders with...more
5/2/2024
/ Acquisitions ,
Best Practices ,
Continuing Legal Education ,
Controlled Foreign Corporations ,
Corporate Taxes ,
Corporate Transparency Act ,
Cross-Border ,
Digital Advertising Tax ,
Digital Goods ,
Energy Tax Incentives ,
Events ,
Family Offices ,
Federal Taxes ,
Foreign Assets ,
Foreign Derived Intangible Income (FDII) ,
Foreign Tax Credits ,
Income Taxes ,
Internet Tax Freedom Act ,
IRS ,
Mergers ,
Multinationals ,
OECD ,
Passive Foreign Investment Company ,
Pillar 2 ,
Reorganizations ,
Research and Development ,
Tax Credits ,
Tax Legislation ,
Tax Liability ,
Tax Litigation ,
Tax Planning ,
Tax Reform ,
Tax Returns ,
Virtual Currency
Section 163(j), as recently amended, may limit a taxpayer’s interest expense deduction. Notice 2018-28, in very general terms, provides interim guidance on the application of Section 163(j).
Importantly, the Notice...more
The US tax treatment of a foreign branch owned by a domestic corporation remains fundamentally the same following the 2017 tax reform legislation. However, the establishment of a new foreign tax credit basket for branch...more
The recent US tax reform act carries potential ramifications for bilateral investment between the United States and China. We take a closer look at how tax reform might affect US multinationals operating in China, Chinese...more
Under Subpart F, certain types of income and investments of earnings of a foreign corporation controlled by US shareholders (controlled foreign corporation, or CFC) are deemed distributed to the US shareholders and subject to...more
The 2017 tax reform legislation added section 250 to the Internal Revenue Code, effectively creating a new preferential tax rate for income derived by domestic corporations from serving foreign markets. The new deduction is...more
The recently enacted 2017 tax reform act imposes a new “base erosion and anti-abuse tax” (BEAT) on large corporations. The BEAT operates as a limited-scope alternative minimum tax, applied by adding back to taxable income...more
A House-Senate conference committee has reached agreement on a compromise version of the Tax Cuts and Jobs Act, which includes substantial changes to the corporate and international business taxation rules. The stage now...more
The Senate has passed its version of the Tax Cuts and Jobs Act, which includes substantial changes to the corporate and international business taxation rules. Senate passage was probably the most significant political and...more
The Senate Finance Committee Chairman’s Mark of the Tax Cuts and Jobs Act includes substantial proposed changes to the corporate and international business taxation rules. While this proposal will evolve further in committee...more
The newly introduced Tax Cuts and Jobs Act is a comprehensive tax reform package that touches virtually every area of the tax law. Though largely consistent with September’s tax reform Framework, new details reveal the...more
The White House and Republican congressional leadership released an outline this week to guide forthcoming legislation on tax reform. This outline will serve as a useful framework in structuring what will be an active, and...more
Substantial tax reform is underway and the business community is intently awaiting details of this activity with the aim of positioning themselves to maximize opportunities and minimize any costs or risks that reform may...more
9/22/2017
/ Business Taxes ,
Corporate Taxes ,
Executive Orders ,
Income Taxes ,
International Tax Issues ,
IRS ,
Multinationals ,
Tax Exemptions ,
Tax Rates ,
Tax Reform ,
Trump Administration ,
Undue Burden
Consistent with prior judicial precedent, the U.S. Court of Appeals for the Fifth Circuit recently applied a literal interpretation of the Subpart F inclusion rules based on the plain meaning of Sections 951 and 956....more