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Finalization of Foreign Tax Credit Rules on Disregarded Payments (Effective Retroactively)

USA - February 22 2022 On January 4, 2022, the U.S. Department of the Treasury and the Internal Revenue Service (IRS) published its third set of final regulations on…

Proposed New Code Sec. 163(n) and Removal of Expense Allocation to GILTI

OECD, USA - December 7 2021 General Removal of Expense Allocation to GILT I The BBBA would largely remove expense allocation to GILTI for foreign tax credit purposes. More…

Puzzling Illustrations of the Administration’s GILT I Proposals

OECD, USA - September 28 2021 This column illustrates the tax results of a few simple fact patterns under the Biden Administration’s proposed revisions to the GILTI regime…

Allocation and Apportionment of Stewardship Expenses

USA - October 21 2020 On September 29, 2020, the US Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued final foreign tax credit…

Keith Hagan, En-Jiun Enrica Ma

Elective GILTI Exclusion for High-Taxed GILTI

USA - August 10 2020 On July 20, 2020, the US Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued final section 951A regulations (“Final…

Robbie Alipour, Enrica Ma