On July 20, 2020, the US Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued proposed regulations (REG-127732-19) (the 2020 Proposed Regulations) that would conform the historic Subpart F...more
8/7/2020
/ CFC ,
Controlled Foreign Corporations ,
Corporate Taxes ,
Federal Trade Commission (FTC) ,
GAAP ,
GILTI tax ,
IFRS ,
Income Taxes ,
IRS ,
New Rules ,
Proposed Regulation ,
Shareholders ,
Subpart F ,
Tax Cuts and Jobs Act ,
Tax Rates ,
U.S. Treasury
Following the 2017 Tax Act, a domestic corporate purchaser of stock in a controlled foreign corporation (CFC) generally will desire to make a section 338(g) election. A section 338(g) election provides a stepped-up basis in...more
New section 59A imposes a minimum tax on domestic corporations with substantial amounts of deductible payments made to related foreign persons (referred to as the base erosion and anti-abuse tax, or BEAT). The BEAT can apply...more
The 2017 tax act expanded Subpart F to require an inclusion in income of “global intangible low-taxed income” (GILTI) of a controlled foreign corporation (CFC). This is generally the amount of a CFC’s income in excess of its...more