Ideas & Insights

House Ways and Means issues its discussion draft amendment with revenue items to offset $3.5 trillion spending package.

Senate Finance Chairman Wyden unveils draft international tax reform bill that would overhaul GILTI, FDII and BEAT rules.

Double tax on dividends received by United States shareholders from foreign corporations addressed via TJCA through section 962.

Doing business overseas may trigger unexpected tax consequences, but careful planning can help mitigate the tax bite.

As manufacturing companies rethink their global footprint, they have to bear in mind the changes in tax rules that target global income.

The IRS has recently released new draft instructions for schedules K-2 and K-3 for international tax reporting purposes.

G-7 agreement on a 15% global minimum tax could end the race to the bottom in global taxation, but global and U.S. outlooks remain complex.

During conversations on Saturday June 5, 2021, the G7 made historic strides toward multilateral agreement on a 15% global minimum tax rate.

Mexico bans subcontracting arrangements. Companies need to act by Aug. 23 2021 to avoid tax, legal and judicial consequences.

The international tax landscape is shifting based on recent reports from the White House, Senate Finance Committee and U.S. Treasury.

Mexico released tax changes for 2021. Some new rules may have significant impact on U.S. companies doing business in Mexico.

Partially finalized regulations on business interest expense deductions provide helpful clarifications for multinational businesses.

Taxpayers should familiarize with Biden’s plan, remain vigilant for developments and position themselves to act at the appropriate times.

The CARES Act enacted a temporary suspension of the TCJA’s 80% limitation on the use of NOLs, this will impact FTC and ODL calculations.

Tax planning opportunities for consideration in light of COVID-19, the resulting economic crisis, and evolving tax laws and regulations.

IRS releases final and proposed regulations on the deduction for dividends from foreign corporations and related reporting rules.

Former Vice President Joe Biden’s tax plan features significant changes. Rates seem likely to rise, even if President Trump wins re-election

Final regulations generally taxpayer-favorable versus 2018 proposal, additional proposed regulations give guidance on pass-throughs, others.

Final and proposed regulations related to the GILTI high tax exclusion and subpart F high tax exception released.

Treasury and the IRS have issued final regulations on determining the amount of the deduction for FDII and GILTI.