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May 24, 2019

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

The Tax Cuts and Jobs Act (TCJA) established a “participation exemption system” under which certain earnings of a foreign corporation can be repatriated to a corporate U.S. shareholder without U.S. tax. (This occurs under Internal Revenue Code Section 245A.) (more…)

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Categories: International Business Issues, Spring 2019
Tags: Domestic Corporation, FDII, GILTI, international tax,
By ASL Guest
•
November 12, 2018

Corporations Are Expanding Globally, Without Leaving the US

By Sylvia Chan, CPA, Tax Manager

The Tax Cut and Jobs Act (TCJA), P.L. 115-97 enacted in December 2017 has brought about exciting changes to the tax world.  I would like to draw your attention to a provision that was written specifically to encourage U.S. companies to expand their operations globally without leaving the United States.  Some technology companies have moved their intangible assets offshore to low-income tax jurisdictions and shifted the related income outside the United States.  While tax-avoidance may not always be the primary motive, it was an inevitable truth that the U.S. Treasury was losing a portion of its revenue due to this income shifting tactic.  (more…)

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Categories: Fall 2018, Updates & Alerts
Tags: FDII, Foreign Derived Intangible Income, GILTI, Global Intangible Low-Taxed Income,

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