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Entries by Katherine Malarsky, Laura Gualdoni

New International Regulations Provide Additional Guidance on Tax Reform

Posted 4:30 PM by
The IRS recently issued a new set of final and proposed regulations impacting many international tax concepts introduced as part of the Tax Cuts and Jobs Act (TCJA). As a refresher, the TCJA enacted section 951A, often known as Global Intangible Low-Taxed Income (GILTI), and requires a U.S. shareholder of a Controlled Foreign Corporation (CFC) to include certain income earned by a CFC in taxable income annually. The shareholder’s GILTI inclusion is the sum of the shareholder’s aggregate tested income in excess of tested loss, with certain modifications, calculated based on the proportional interest in all CFCs in which the shareholder held during the tax year.
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New Requirements for Tracking International Affiliates and Rental Real Estate: BE-10 Report

Posted 5:45 PM by
The rules related to BE-10 filing requirements have changed this year and will require additional people (“Reporters”) to complete this informational form. Every five years, the Bureau of Economic Analysis (BEA), part of the U.S. Department of Commerce, conducts a survey to analyze the extent of U.S. persons’ direct investment abroad. Specifically, this year’s filing change relates to U.S. persons that own foreign affiliates and/or foreign rental real estate being required to file, regardless of being notified.
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The Increased Importance of Income Sourcing in a Post-Tax Reform World

Posted 8:00 PM by
The Tax Cuts and Jobs Act of 2017 (TCJA), signed into law in late 2017, included significant changes to the tax environment in the United States. One of the largest changes was the addition of the qualified business income (QBI) deduction. The QBI deduction allows for a deduction of up to 20 percent of the qualified business income from partnerships, limited liability companies (LLCs), S corporations, trusts, estates, and sole proprietorships. Learn more about the QBI deduction.
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