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IMPACT OF RULE CHANGES FOR US SHAREHOLDERS ON DEEMED DISTRIBUTIONS FROM CFCs

July 29, 2020

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

CONGRESS PASSES YEAR-END TAX EXTENDER PACKAGE

December 20, 2019

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

IRS Grants Relief for U.S. Persons Who Own Stock in Certain Foreign Corporations

October 2, 2019

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

September 16, 2019 Due Date to Change and/or Avoid Penalties on GILTI Income

August 27, 2019

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

Final GILTI..

GILTI Relief for US Individuals Who Own Foreign Companies

March 7, 2019

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

IRS Releases New Foreign Tax Credit Form (Hint:  It Is Not Just for Corporations)

January 14, 2019

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

Guidance on the GILTI Provision

October 9, 2018

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

Does the Global Intangible Low-Taxed Income (GILTI) Provision Work?

August 1, 2018

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

FAQ on Deemed Repatriation from US Owned Foreign Corporations

June 6, 2018

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

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