Proposed New Regulations on Foreign Tax Credits (FTC)

On November 28, 2018, the US Department of Treasury (“Treasury”) and Internal Revenue Service (“IRS”) released proposed regulations (“Proposed Regulations”)1 on the determination of foreign tax credits, which is related to the global intangible low-taxed income (GILTI) regime and other changes made by last year’s tax reform legislation, known as the Tax Cuts and Jobs

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It’s Tax Season – How new changes to TCJA affect you

IRS has posted a useful comparison of nineteen tax changes for business in the Tax Cuts and Jobs Act (“TCJA”). TCJA changed deductions, depreciation, expensing, tax credits and other tax items that affect businesses. This side-by-side comparison can help businesses understand the changes and plan accordingly. Some provisions of the TCJA that affect individual taxpayers can also

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What is GILTI?

The Global Intangible Low-taxed Income (GILTI) is a new provision, enacted as a part of the Tax Cuts & Jobs Act (TCJA) tax reform legislation. The provision defines GILTI income as the amount of income earned by a U.S. foreign subsidiary above a certain threshold amount. Under the TCJA, a U.S. person (includes U.S. individuals,

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Do I need to worry about “One Time Transition Tax”?

As of January 1, 2018, the 2017 Tax Cuts & Jobs Act (TCJA) changes the taxation regime for U.S. multinational corporations. The international provisions in TCJA introduce a new territorial system for the taxation of foreign company income.  Before these new tax provisions take effect, the new law imposes a mandatory one-time tax (the “Transition

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How Will the New Territorial Tax System Affect U.S. Competitiveness?

Introduction The recently enacted 2017 Tax Reform Act embraces major sweeping changes to US international tax rules. President Donald J. Trump has endorsed large changes to the federal tax code, and as per sources, the steps such as lowering rates for individuals and corporations, and further changing the taxation of overseas profits, will increase the

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