On November 12, 2020, the US Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) published proposed regulations (REG-101657-20) (the “2020 Proposed Regulations”) in the Federal Register that contain a...more
On July 23, 2020, the US Department of the Treasury and the Internal Revenue Service (IRS) published final regulations addressing the global intangible low-taxed income (GILTI) high-tax exclusion (85 FR 44620) (the “Final...more
8/10/2020
/ CFC ,
Federal Trade Commission (FTC) ,
Foreign Tax ,
GILTI tax ,
Income Taxes ,
IRS ,
Proposed Regulation ,
Record Retention ,
Shareholders ,
Subpart F ,
Tax Cuts and Jobs Act ,
U.S. Treasury
Changes made by tax reform have caused companies to reevaluate their structures. This reevaluation extends to the most fundamental decision: choice of entity. The choice of entity decision now frequently hinges on two key,...more