IRS Releases Final Regulations under Section 250
Posted on Jul 9, 2020 in International Tax
On July 9, the Internal Revenue Services issued final regulations under section 250. Section 250 provides a deduction for both foreign-derived intangible income (FDII) and global intangible low-taxed income (GILTI). The final regulations address the documentation and substantiation requirements with respect to the deduction under section 250. Read More: IRS Releases Final FDII, GILTI...
OIRA Completes Review of Final Regulations under Section 250
Posted on Jun 15, 2020 in International Tax
On June 12, the Office of Information and Regulatory Affairs (OIRA) completed its review of final regulations under section 250. Section 250 generally allows a domestic corporation a deduction for its foreign-derived intangible income (FDII) and its global intangible low-taxed income (GILTI) inclusion. The proposed regulations were published in the Federal Register on March 6, 2019....
OIRA Begins Review of Final Regulations under Section 250
Posted on May 28, 2020 in International Tax
The Office of Information and Regulatory Affairs (OIRA), part of the Office of Management and Budget, has begun its review of final regulations under section 250. Section 250 generally allows a domestic corporation a deduction for its foreign-derived intangible income (FDII) and its global intangible low-taxed income (GILTI) inclusion. The proposed regulations were published in the...
Treasury Intends to Finalize All Major TCJA Guidance by October 1
Posted on Feb 21, 2020 in International Tax
Speaking at a conference yesterday, Chip Harter, Treasury deputy assistant secretary for international tax affairs, stated that he is “fairly confident” that Treasury will be able to finalize all major guidance related to the Tax Cuts and Jobs Act by October 1st of this year. With respect to timing, Harter stated that he expects that regulations under section 901(m) will be released...
IRS Releases Proposed Regulations Addressing the FDII and GILTI Deduction under Section 250
Posted on Mar 4, 2019 in International Tax, Uncategorized
On March 4, 2019, the IRS released proposed regulations under section 250. Section 250 generally allows a domestic corporation a deduction for its foreign-derived intangible income (FDII) and its global intangible low-taxed income (GILTI). The proposed regulations provide rules for determining the amount of the deduction, including guidance related to the provision’s taxable income...
OIRA Receives Proposed Section 163(j) Regulations for Review
Posted on Oct 26, 2018 in Individual Taxation, International Tax, News, Pass-through Taxation, Tax Accounting
The Office of Information and Regulatory Affairs (OIRA) received draft proposed regulations under section 163(j), addressing the limitation on business interest deductions, on October 25, according to the Office of Management and Budget’s website. As amended by the Tax Cuts and Jobs Act (TCJA), section 163(j) generally limits business interest expense deductions to the sum of business...
AICPA and CIMA US Tax Reform Conference 2018
Posted on Aug 7, 2018 in International Tax
Eversheds Sutherland is the proud lead sponsor of the Association of International Certified Professional Accountants (AICPA) and the Chartered Institute of Management Accountants (CIMA) US Tax Reform Conference 2018 on September 17, 2018, at the Jumeirah Carlton Tower Hotel in London, United Kingdom. The US and International Eversheds Sutherland Tax team will be chairing the event and...
Regulations and Notices to Provide Guidance on New Tax Bill
Posted on Feb 5, 2018 in International Tax, News
As the early guidance period for the new tax bill continues, the Treasury and IRS plan to shift to focusing on developing regulations over the next six months. A less notice-oriented approach is expected, with only five to ten limited-scope notices addressing basic questions, such as section 163(j) business interest issues, anticipated. IRS and Treasury tax reform projects will be...