Featured Analysis
Nana Ama Sarfo looks at how adoption of comments on the Treasury Department's proposed partnership withholding regulations might substantially expand the regime.
In economic analysis, Martin A. Sullivan offers a few generalizations about the tax treatment of global intangible low-taxed income, providing calculations on the effect of changes in profit movement on taxes.
Carrie Elliot describes how the proposed subpart F regulations and the final global intangible low-taxed income regulations still apply a hybrid standard that characterizes domestic partnerships as both aggregates and entities.
Carrie Elliot describes how new proposed regs allow taxpayers to elect an exclusion from global intangible low-taxed income for controlled foreign corporation’s high-taxed income.
In news analysis, Marie Sapirie attempts to parse the differences in the term “substantially all,” as the same phrase in the same statute has two different numerical thresholds.
In the second part of her series, Carrie Brandon Elliot describes how the section 245A temporary regulations limit dividends received deductions when domestic corporate shareholders have extraordinary reductions in their CFC stock ownership.
Mindy Herzfeld continues her series on guidance interpreting the Tax Cuts and Jobs Act, focusing on questions left unresolved by final and proposed regulations.
In economic analysis, Martin A. Sullivan explains a spreadsheet he provides as a tool to help with the complexity inherent in the Tax Cuts and Jobs Act’s new international provisions.
Benjamin M. Willis considers statutory abuse under the Tax Cuts and Jobs Act, arguing that regulations issued more than 18 months since the TCJA’s enactment must meet a high threshold to comport with U.S. limits on ex post facto rules.
In news analysis, Nana Ama Sarfo looks at the tax landscape for inversions post Tax Cuts and Jobs Act and in light of the AbbVie/Allergan announcement