Articles

Results 1 to 5 of 15
Most popular |Most recent


Government Revises Base Difference Rules in New Foreign Tax Credit Regulations

USA - November 3 2020 The 2019 Proposed Regulations provided a detailed framework for allocating and apportioning foreign taxes that was generally…

Bradford E. LaBonte, En-Jiun Enrica Ma.

The GILTI High-Tax Exclusion and the Tested Unit Standard: New Administrative Burdens Await for Taxpayers

USA - August 10 2020 On July 23, 2020, the US Department of the Treasury and the Internal Revenue Service (IRS) published final regulations addressing the global…

Timothy S. Shuman.

Benefits of a Section 338 Election to a US Buyer of CFC Stock

USA - November 15 2018 The 2017 Tax Act significantly increased the benefits of a section 338(g) election for a domestic corporate purchaser of stock in a controlled foreign…

Jonathan Lockhart, Lowell D. Yoder, Timothy S. Shuman.

Selling CFC Stock: A Buyer’s Section 338 Election Can Be Beneficial

USA - November 1 2018 Following the 2017 Tax Act, a domestic corporate purchaser of stock in a controlled foreign corporation (CFC) generally will desire to make a section…

Jonathan Lockhart, Lowell D. Yoder, Timothy S. Shuman.

Tax Reform Insight: US Tax Costs Significantly Reduced on Sale of CFC Stock

USA - September 13 2018 Following the 2017 Tax Act, the US tax costs to a corporate US shareholder that sells stock in a controlled foreign corporation (CFC) are…

Jonathan Lockhart, Lowell D. Yoder, Timothy S. Shuman.