Example:Let’s say an individual small business owner owns 100% of a U.K. corporation with no fixed assets. This corporation earns $100,000 in 2018, none of which is Subpart F income. It pays no dividends to its owners. Before tax reform, the business owner didn’t have to worry ab...
What is clear is that recent proposed regulations are barely a preview of coming attractions in GILTI guidance. While guidance is generally welcome in this brand-new area—the application of GILTI on a group basis for consolidated groups is helpful instruction, for example—even this first round ...
Some departures from the proposed regulations were made to reflect changes made in other regulations. For example, in light of the December 2019 proposed regulations relating to foreign tax credits (2019 Proposed FTC Regulations), the final regulations make changes to how certain expenses are apportio...