Featured Analysis
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
In news analysis, Benjamin M. Willis examines the final global intangible low-taxed income regulations and related planning concerns and considerations.
Carrie Brandon Elliot reviews how the unintended consequences of hybrid regulations can reflect overreach as applied to notional interest deductions and group relief, and incompleteness as applied to inclusions under the global intangible low-taxed income and subpart F regimes.
In news analysis, Marie Sapirie argues that while Treasury guidance regarding the withholding on transfers of partnership interests has been helpful in providing rules for the withholding regime, there are still significant issues to be addressed before the regime is fully workable.
Carrie Brandon Elliot reviews the introduction of hybrid deduction accounts in the section 245A(e) proposed regulations and notes that Treasury may consider expanding this concept to GILTI and subpart F.
In news analysis, Mindy Herzfeld examines a letter from the European Commission commenting on proposed regulations interpreting section 250, saying the commission’s reliance on a single report ignores historical nuances and that whether a tax measure can be considered a violation of a trade agreement because of its economic consequences is better analyzed within the context of the overall U.S. system.
Carrie Brandon Elliot describes the new foreign tax credit limitation expense allocation and apportionment proposed regulations — including the role of new sections 951A (global intangible low-taxed income) and 245A (participation exemption).
In economic analysis, Martin A. Sullivan argues that Congress should pay for a lower effective tax rate on global intangible low-taxed income by increasing the 20 percent haircut on foreign creditable taxes, increase the haircut on foreign tax credits in 2026 instead of reducing the section 250 deduction, and reduce foreign tax creditability instead of raising the rate.
Carrie Brandon Elliot describes how the proposed regs related to section 163(j) seek to help taxpayers avoid mismatches and double-counting.
In news analysis, Nana Ama Sarfo reviews arguments explaining why GILTI design flaws have created stumbling blocks for taxpayers and practitioners alike.