The law known as the Tax Cuts and Jobs Act of 2017 (TCJA) made many significant changes to the international tax regime. One important change is Sec. 250, which was enacted by Section 14202(a) of the TCJA, and generally provides a domestic C corporation (1) a deduction for its foreign-derived intangible income (FDII) for the tax year, and (2) a deduction for its Sec. 951A global intangible low-taxed income (GILTI) inclusion for the tax year. To read the full article in The Tax Advisor, click: Foreign-Derived Intangible Income Guidance Addresses Many Open Questions.
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It has been over a year since the law known as the Tax Cuts and Jobs Act (TCJA) was passed. Taxpayers and tax advisers are continuing to peel back its layers of complexity to understand the various provisions. Taxpayers with state tax obligations and state tax practitioners face an additional challenge of understanding the implications of the new or amended federal provisions on state taxation. To read the full article in The Tax Adviser, click: The TCJA and State Considerations for Business.
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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.