The IRS issued proposed regulations that Sec. 956, which requires an income inclusion by U.S. shareholders of controlled foreign corporations (CFCs) that invest in U.S. property, should not apply to corporate shareholders. To read the full article in Journal of Accountancy, click: Proposed Rules Would Exempt Corporate U.S. Shareholders from Sec. 956.
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The IRS proposed new rules under the global intangible low-taxed income (GILTI) provision (Sec. 951A) added by the Tax Cuts and Jobs Act. Sec. 951A requires U.S. shareholders of controlled foreign corporations (CFCs) to include in their gross income their GILTI income for that tax year (the inclusion amount). The new provision applies to tax years of foreign corporations beginning after Dec. 31, 2017, and to the U.S. shareholders’ tax years within which the foreign corporations’ tax years end. To read the full article in the Journal of Accountancy, click: IRS Issues Proposed Regs for GILTI Inclusions.
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Although some types of entities have required tax years, not all do. Karen Messner helps you find out how to adopt a tax year other than a calendar year by planning ahead. To read the full article in the The Tax Adviser, click: Accounting Period Planning may Provide Preferred Year.