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Entries by ryan-miller

Final GILTI Regulations Provide Some Relief to Taxpayers

Posted 1:15 PM by
The Tax Cuts and Jobs Act of 2017 added a new anti-deferral rule known as Global Intangible Low-Taxed Income (GILTI). The GILTI provisions impact taxpayers that own an interest in certain foreign corporations that are classified as controlled foreign corporations (CFC). Below is a brief background on the basic GILTI rules as well as highlights of significant developments in the final regulations that were issued in June 2019.
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Determining the Category of Filer for Form 5471 With Respect to Ownership of Foreign Corporations

Posted 5:30 PM by
The Tax Cuts and Jobs Act (“TCJA”) that was passed at the end of 2017 was meant to simplify the tax code. However, in the international tax realm, the complexity has only increased. This is certainly true of the revised form and instructions for Form 5471, Information Return of U.S. Persons With Respect to Certain Foreign Corporations, as of December 12, 2018 for the 2018 tax filing season. These revisions significantly change the form, and the instructions expand the categories of filers for this form.
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Tax Reform: Nondeductible Parking Expenses and Their Impact on Your Business

Posted 12:53 PM by
The Tax Cuts and Jobs Act (TCJA) provides that expenses for qualified transportation fringe benefits are nondeductible. The IRS recently released interim guidance via Notice 2018-99 clarifying that a portion of taxpayers’ “parking expenses” is considered nondeductible as qualified transportation fringes. Thus, Notice 2018-99 has significantly expanded the number of taxpayers that will need to calculate the nondeductible portion of their parking expenses. Now, all employers that own or lease a parking lot where their employees park will need to consider if an add-back to taxable income is required. This provision impacts the preparation of 2018 tax returns as it applies to expenses incurred or paid after Dec. 31, 2017.
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New GILTI Rules Target U.S. Shareholders of Controlled Foreign Corporations

Posted 2:30 PM by
As a general rule, the earnings of a foreign corporation are not subject to U.S. taxation until such earnings are distributed as dividends. The Subpart F rules have long been in place to subject the earnings of a controlled foreign corporation (CFC) to U.S. taxation whether or not such earnings are actually distributed. The tax reform legislation passed in Dec. 2017 imposed an additional anti-deferral rule referred to as GILTI (Global Intangible Low-Taxed Income). The new GILTI inclusion rules function in a manner similar to the existing Subpart F regime.
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Litigation Activity Keeps Spotlight on Reporting of Foreign Financial Accounts

Posted 12:00 PM by
With penalties including monetary fines and possible jail time, the Internal Revenue Service (IRS) and Department of the Treasury have shown how seriously they treat violations related to foreign financial account reporting. Considering such tough penalties, it is critical to understand who is required to file, what information is needed, and how recent cases could impact you.
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New Guidance for Complying with Code Section 965 – Deemed Repatriation

Posted 4:00 AM by
The IRS has released guidance related to Code Section 965 which was added by the Tax Cuts and Jobs Act of 2017 (TCJA). Code Section 965 imposes a transition tax that calendar year taxpayers must pay with their 2017 tax returns if they have investments in certain specified foreign corporations. The guidance is provided via Frequently Asked Questions (FAQ) posted to the IRS website.
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Tax Reform Offers New Employer Credit for Paid Family and Medical Leave

Posted 5:00 AM by
The Tax Cuts and Jobs Act introduced a new general business credit for employers that pay employee wages during time away from work under the Family and Medical Leave Act (FMLA). The paid family and medical leave credit can be used to reduce a taxpayer’s alternative minimum tax. However, the new credit will not apply to wages paid in tax years beginning after Dec. 31, 2019.
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2017 Tax Reform: Key International Tax Provisions

Posted 4:19 PM by
The tax reform bill (“Tax Cuts and Jobs Act”) has now been passed by both houses of Congress and is expected to be signed into law by President Trump in the coming days. Below is a look at the final provisions relating to concepts of international taxation, including a summary of the most significant and broadly applicable changes.
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Section 987 Regulations: Implementation Delay

Posted 5:00 AM by
The Internal Revenue Service (IRS) recently announced in Notice 2017-57 that it will defer the effective date of the final Treasury Regulations related to Section 987 by one year (effective for tax years beginning Jan. 1, 2019). This is pursuant to the Executive Order that President Trump gave to the Treasury in April 2017 to identify and reduce tax regulatory burdens.
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Combating Double Taxation: Foreign Tax Credits and Tax Treaties

Posted 4:00 AM by
The foreign tax credit and its application is complex and can vary widely when looking at state tax liabilities, and the application of tax treaties against state liabilities. A taxpayer that earns income abroad may potentially be subject to double taxation, making the foreign tax credit and tax treaties an important part of the tax filing process.
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