Treasury and IRS Release Final and Proposed Regulations under Section 163(j)
Posted on Jul 28, 2020 in Uncategorized
On July 28, the Department of the Treasury and the Internal Revenue Service released final and proposed regulations under section 163(j). Amended by the Tax Cuts and Jobs Act (TCJA), section 163(j) generally limits a taxpayer’s interest deduction to the sum of its business interest income, floor plan financing interest, and 30% of its adjusted taxable income. The provision was further...
IRS Issues Final and Proposed Regulations with Respect to the GILTI and Subpart F High-Tax Exclusions
Posted on Jul 20, 2020 in International Tax
On July 20, the IRS released final regulations that allow taxpayers to elect out of the global intangible low-taxed income (GILTI) provisions if the income is subject to a rate of at least 18.9% in a foreign country. Proposed regulations were also released that generally would revise the subpart F high-tax exception to be consistent with the provisions of the GILTI high-tax exception....
OIRA Completes Review of Final Regulations on the GILTI High-Tax Exclusion
Posted on Jul 9, 2020 in International Tax
On July 7, the Office of Information and Regulatory Affairs (OIRA) completed its review of final regulations under section 951A relating to the proposed high-tax exclusion for global intangible low-taxed income (GILTI) and its review of proposed regulations under section 954(b)(4) relating to high-tax subpart F income. Among other provisions, the proposed version of the regulations had...
IRS Releases Final Regulations under Section 250
Posted on Jul 9, 2020 in International Tax
On July 9, the Internal Revenue Services issued final regulations under section 250. Section 250 provides a deduction for both foreign-derived intangible income (FDII) and global intangible low-taxed income (GILTI). The final regulations address the documentation and substantiation requirements with respect to the deduction under section 250. Read More: IRS Releases Final FDII, GILTI...