The 2017 Tax Act significantly increased the benefits of a section 338(g) election for a domestic corporate purchaser of stock in a controlled foreign corporation (CFC). If an election is made, the Buyer is treated as...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
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
Regulatory Developments Under § 367 Affecting Transfers of Appreciated Property to Foreign Corporations -
Introduction:
On September 14, the U.S. Department of the Treasury (Treasury) and the Internal Revenue...more
10/5/2015
/ Administrative Procedure Act ,
Amended Regulation ,
BEPS ,
Clawbacks ,
Controlled Foreign Corporations ,
Corporate Taxes ,
Cost-Sharing ,
Foreign Corporations ,
Goodwill ,
Intangible Property ,
IRC Section 367 ,
IRS ,
Partnerships ,
Proposed Regulation ,
Section 482 ,
Stock-Based Compensation ,
Tax Court ,
Tax Reform ,
Transfer Pricing ,
Transfers ,
U.S. Treasury