International Tax News

Proposed Regs to Determine FDII

Proposed Regs Set Out How to Determine FDII In March, the IRS issued proposed regulations that cover determining the amount of the deduction for foreign-derived intangible income (FDII) and global intangible low-taxed income (GILTI). The regs also coordinate the FDII and GILTI deduction with other tax provisions. In this article, we’ll review what led to…

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Proposed Regs on the FDII and GILTI Deduction

An Overview of the Proposed Regs on the FDII and GILTI Deduction In March, the IRS issued proposed regulations that cover determining the amount of the deduction for foreign-derived intangible income (FDII) and global intangible low-taxed income (GILTI). The regs also coordinate the FDII and GILTI deduction with other tax provisions. Here’s an overview. Background…

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Section 965 Transition Tax Forms and Instructions Now Available

Section 965 Transition Tax Forms and Instructions Now Available In late January, the IRS issued a series of forms and instructions regarding the Internal Revenue Code Section 965 transition tax provision, which was added by the Tax Cuts and Jobs Act. Here’s an overview of the pertinent paperwork. Primary Requirements Sec. 965 generally requires U.S….

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IRS Determines Correct Functional Currency To Calculate Foreign Currency Exchange Gain or Loss

IRS Determines Correct Functional Currency To Calculate Foreign Currency Exchange Gain or Loss In a Technical Advice Memorandum (TAM) issued in February, the IRS determined which of two currencies was the correct functional currency to calculate any foreign currency exchange gain or loss under Internal Revenue Code Section 988. The TAM revolved around payments of…

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Tax Court Thwarts Use of Rule 155

Tax Court Thwarts Use of Rule 155 to Raise New Issues In Vento et al., a case decided in February, the U.S. Tax Court has held that the taxpayers involved couldn’t use Tax Court Rule 155 to raise new issues in litigation where they were denied foreign tax credits under Internal Revenue Code Section 901…

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