AGG Talks: Cross-Border Business - U.S. Tax Considerations for Scaling Across Borders
Podcast: Illinois Tool Works Inc. & Subsidiaries v. Commissioner of Internal Revenue
The Final Rule prohibits or requires notification of certain US investments in Chinese and Chinese-controlled entities involved in semiconductors, quantum information technologies, and artificial intelligence....more
On May 6, 2024, the U.S. Department of the Treasury (Treasury) and Internal Revenue Service (IRS) published final regulations (Final Regulations) regarding clean vehicle tax credits under Internal Revenue Code sections 25E...more
Recently released final regulations provide some relief to taxpayers that are subject to high foreign taxes on their global intangible low-taxed income (GILTI), but whether the GILTI high-tax exclusion is beneficial to any...more
The final regulations addressing the GILTI high-tax exception retain the general approach of the proposed regulations with some simplifying changes. Key Points: ..Taxpayers can elect on an annual basis whether to...more
On December 2, 2019, Treasury and the IRS released final and proposed regulations on the foreign tax credit. As expected, the final regulations finalize the 2018 proposed regulations relating mainly to the Tax Cuts and Jobs...more
Final regulations relating to the determination of the foreign tax credit following the Tax Cuts and Jobs Act were released earlier this month. Though largely similar to the proposed regulations, taxpayers may be interested...more
On December 2, 2019, the U.S. Department of the Treasury (“Treasury”) and the Internal Revenue Service (“IRS”) issued a pre-published version of final regulations (the “Final Regulations”) providing guidance with respect to...more
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of June 10 – 14, 2019. June 11, 2019: The IRS issued a news release noting that it and the US...more
Section 956 final regulations confirm those eligible for territorial dividend exemption can benefit from foreign guarantee and collateral support without incurring US tax. On May 23, 2019, the US Treasury and Internal...more
Implements 2018 Proposed Regulations, ending most limitations on investments in U.S. property, as well as pledges and guarantees by CFCs wholly-owned by U.S. corporations – also provides PTI guidance for CFC shareholders. ...more
On May 22, 2019 the Treasury Department and the Internal Revenue Service released regulations (the “Final Regulations”) finalizing and making certain technical changes to proposed regulations (the “Proposed Regulations”,...more
On March 18, 2019, the U.S. Department of the Treasury and the Internal Revenue Service issued final tax regulations for registered investment funds that are taxed as regulated investment companies (“RICs”) and that invest in...more
On March 19, 2019, the Internal Revenue Service (IRS) and Treasury Department (Treasury) issued final regulations (T.D. 9851) (Final Regulations) under section 851 addressing the income test applicable to regulated investment...more