Recent changes may eliminate some of the deemed distributions from controlled foreign corporations..

GILTI, Tax, International Tax

DOES NOT INCLUDE TECHNICAL CORRECTIONS RELIEF FOR THE “DOWNWARD ATTRIBUTION” PROBLEM CREATED BY THE..

GILTI, Tax

The Internal Revenue Service issued Revenue Procedure 2019-40 and proposed regulations that provide..

GILTI, Tax, Transition Tax

Impacts Partners and S Corporation Shareholders with Less Than 10% Interest in CFCs

Final GILTI..

GILTI

On March 5^th, 2019 the IRS released the latest installment of proposed regulations (the “Proposed..

GILTI, Tax

The IRS has released a new Form 1118, “Foreign Tax Credit — Corporations,” and new instructions..

GILTI, Tax, Transition Tax

Now that the Transition Tax is (almost) behind us, US Shareholders of foreign corporations..

GILTI

The Tax Cuts and Jobs Act (TCJA), passed in December of 2017, was aimed at encouraging..

GILTI

The Tax Cuts and Jobs Act (TCJA) that was enacted on December 22, 2017, includes a deemed..

GILTI, Tax