Podcasts about fdii

Companies scored wins after the House passed a multi-trillion-dollar tax bill that largely preserved the current tax rates on foreign-earned income. Republicans' 2017 Tax Cuts and Jobs Act created a new international tax regime including a minimum tax on global intangible low-taxed income, or GILTI, a reduced tax rate on foreign-derived intangible income, or FDII, and a base erosion and anti-abuse tax, or BEAT. Each of these tax rates will go up in 2026 without congressional action, but House lawmakers made slight changes that will result in minimal tax increases. But the debate isn't over. The bill now heads to the Senate, where tax practitioners and companies expect impactful changes to the mammoth legislation, including the international provisions. On this week's episode of Talking Tax, reporter Lauren Vella talks about the House provisions, what companies want to see in the Senate version of the tax bill, and how the legislation might impact US relations with other countries. Do you have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.

On the latest episode of Beyond the Numbers by Weaver, host Vince Houk, Partner-in-Charge, International Tax Services at Weaver, delves deep into the world of strategic transfer pricing and how businesses can use it to their advantage. Joining him is Josh Finfrock, Director, Transfer Pricing Services at Weaver, an expert with a wealth of knowledge in the field. Key Points: One overlooked opportunity in utilizing FDII is to analyze the expense allocation with GNA expenses and allocate accordingly based on genuine benefit, which can help derive a better benefit. Other opportunities include looking at services provided by the U.S. company that may qualify for the FDII benefit and reviewing the IP structure to potentially move IP into the U.S. The U.S. provides a jurisdiction with substance, a good treaty network, and potentially lower tax rates compared to other countries, making it an attractive option for IP ownership and maintaining key operations. How can firms shift their perception and utilize transfer pricing as an asset rather than a burden? And what lies beyond the surface of transfer pricing, and how can businesses harness its potential to enhance their global operations? Clients often overlook how strategic transfer pricing can be and how it can be a tax saver and assist in cash management efficiency. For example, there is cash repatriation leakage that can be planned around with transfer pricing. Rate differentials between countries can be another challenge that transfer pricing adjustments can help save. Finfrock stated, “If we can do a strategic transfer pricing review with the company, we're going to come in and be able to look at, get a holistic view of the company, the global structure, understand where all the moving pieces are. That way, then we really know where those levers are, what our range of outcomes can be in different places, and then we can find those opportunities for savings.” Subscribe and listen to future episodes of Beyond the Numbers on Apple Podcasts or Spotify. ©2023

In this episode of Weaver: Beyond the Numbers, On the Shop Floor podcast hosts Colby Horn and Kurtis Dixon examine the world of export incentives with Vince Houk, Weaver's partner-in-charge, International Tax Services. Together they discuss how companies can leverage these benefits to reduce taxes, offset costs and optimize their financial strategies.Key Points: • Export incentives yield permanent tax savings• IC-DISC and FDII offer tax advantages for international sales• Effective use of incentives boosts financial gainsExport incentives have emerged as a pivotal tool for companies, especially those in the M&D sector selling goods outside the U.S. These incentives offer permanent tax savings and mitigate unfavorable legislative changes such as R&D capitalization. This episode explores how businesses can maximize benefits, particularly after recent tax code changes. Vince emphasizes the importance of these incentives, specifically for maximizing benefits to offset costs. He further elaborates on the two main incentives from an export perspective, IC-DISC and FDII, explaining their nuances and potential benefits for different entities. IC-DISCs are for companies that manufacture in the U.S. and sell internationally. FDIIs are specifically for C corps that sell products outside of the U.S. to a foreign person for foreign use. With many clients engaging in significant international sales, Weaver regularly helps companies feel comfortable moving forward with these benefits. Subscribe and listen to future episodes of Weaver: On the Shop Floor on Apple Podcasts or Spotify.©2023

monthly review of US international tax-related developments. In this edition: US budget reconciliation remains stalled, but some behind-the-scenes talks – Senators introduce Support Ukraine Through Our Tax Code Act -- More US FTC guidance coming – US officials offer international tax projects update – IRS GLAM addresses allocating/apportioning ‘deferred compensation expense' for FDII deductions – Changes to QI withholding agreement rules expand QI W/H and reporting responsibilities – OECD officials offer BEPS 2.0 update – OECD issues recommendations to strengthen tax administrations' cooperation re international rules, including BEPS 2.0 – OECD releases public consultation on Regulated Financial Services Exclusion under Amount A for Pillar One.

A review of the week's major US international tax-related news. In this edition: US House leaders hope to pass “China competitiveness” bill before 4 July recess – Senate introduces bill to disallow foreign tax credits (FTCs) for taxes paid to Russia or Belarus – Treasury, IRS considering changes to FTC regulations – IRS proposed Section 1256 regulations on FX contracts set for release in coming weeks, Section 987 rules to follow – IRS issues GLAM on allocation and apportionment of deferred compensation expense for FDII deductions, reverses prior guidance – Treasury, OECD officials offer BEPS 2.0 insights.

The latest version of the Build Back Better bill was released by the U.S. House of Representatives on November 5, 2021. The bill includes significant spending initiatives which are paid for, in part, by proposed tax provisions that impact companies operating outside the United States. Tax Beat hosts, Brooks and Sarah, invite Cherry Bekaert's International Tax specialists, Brian Dill and Michael Cornett, to highlight the proposed provisions impacting income subject to GILTI and FDII tax rates. They also address other proposed provisions including changes to foreign tax credits and BEAT. This is timely information as companies evaluate changes to their supply chains and watch the movement towards a global minimum tax.A companion Tax Beat podcast highlights the proposed tax provisions that can impact businesses and individual taxpayers. Chapter Marks:7:14 -- Proposed provisions impacting GILTI and FDII11:18 -- Changes to the foreign tax credit regime13:34 -- Other provisions in and out of the bill18:59 -- State of global minimum tax rate26:42 -- Recommendations for planning

Doug McHoney (PwC's US International Tax Services Co-Leader) is live at the Westminster Studios with Sherry Grabow (PwC's US International Tax Services Co-Leader) to discuss the international tax provisions in the recently released ‘Chairman's Mark' from the House Ways and Means Committee. Doug and Sherry cover, among other topics: Interest expense under new Section 163(n) and existing Section 163(j); changes to foreign derived intangible income (FDII), modifications to the global intangible low-taxed income (GILTI) regime, changes to the foreign tax credit rules; sweeping changes to subpart F income; a refreshed base erosion and anti-abuse tax (BEAT), and how taxpayers should prepare for potential changes to the tax rules.

On September 13, the House Ways and Means Committee and the Joint Committee on Taxation released drafts of proposed tax legislation and estimated budget effects of taxes under the $3.5 trillion budget reconciliation bill.  Many of the provisions in the draft legislation are familiar from President Biden's American Families Plan and American Jobs Plan and Treasury's Green Book released earlier this year.    In this session, Cherry Bekaert's Tax Beat hosts, Brooks and Sarah, walk through highlights of the draft legislation including proposed tax rate changes and the taxpayers who may be impacted.  They also discuss surprises in the draft bill that were not mentioned in the earlier proposals from President Biden, and the effective dates for various provisions.  To close out the discussion, Brian Dill, partner and leader of the Firm's International Tax Practice Team, joins in for a discussion of the proposed legislative changes to FDII, GILTI, foreign tax credits and other tax provisions impacting companies operating within and outside of the U.S.   Chapter Marks:01:30     Background – legislative process - $1.2 T infrastructure08:02     Tax rate changes (effective for tax years beginning after 12/31/2021)11:13     Capital gains (generally effective for transactions on or after September 13, 2021) 14:42     Taxing income from a pass-through business (effective for tax years beginning after 12/31/2021)20:01     Estates and trusts (generally effective for estates and gifts arising after 12/31/2021)22:25     Mega-IRAs (generally effective for tax years beginning after 12/31/2021)24:39     Other Selected Provisions26:30     International Tax Provisions

Brooks and Sarah discuss the potential impact of proposed changes to U.S. based multinational companies with Cherry Bekaert's Brian Dill, Principal and International Tax Leader, and Michael Cornett, Director for International Tax Services. These proposed changes were introduced in the American Jobs Plan and further explained in Treasury's Green Book. The conversation covers proposed changes to FDII, GILTI, anti-inversion, and other tax rules intended to discourage moving business operations off shore. We also discuss the recent G7 and G20 agreements to pursue a 15% minimum global tax rate.  Brian and Mike highlight common themes in tax policies across countries, and we wrap up with a few ideas and actions multinational companies should consider now.The conversation includes:2:45: Overview7:50: American Jobs Plan proposals and Green Book explanations19:55: A 15% global minimum tax rate29:13: Potential Impact to a company's global supply chain35:56: Final commentsRelated Guidance:Tax Beat: Treasury's Green Book Part 1Tax Beat: Treasury's Green Book Part 2Tax Beat: American Jobs Plan, 2021Tax Beat: American Families Plan

In our Forecast 2021 podcast series, we're focused on offering insights to help you better understand and manage some of the opportunities and challenges that your company might face—think policy, technology, and other big picture topics. In this week's episode, we highlight the “Green Book,” which is the Treasury's explanation of the tax proposals in the proposed FY2022 Federal budget. We focus on the proposals that will have a significant impact on corporate income tax policies. Heather Horn sat down with Jenn Spang, PwC's National Office income tax accounting leader, and Pat Brown, co-leader of PwC's Washington National Tax Services group, to discuss the big changes on the horizon. Tax leaders are already scenario planning - we break it down so CFOs can do the same.Topics include:1:03 - “Green Book.” The Treasury Department released the annual tax budget, or the “Green Book,” last month. Pat and Jenn highlight the significant corporate tax proposals and their financial statement impacts.11:07 - GILTI. Pat digs deeper and explains the proposed changes to the global intangible low-taxed income (GILTI) tax policy. Jenn tells us the accounting ramifications.18:30 - BEAT and SHIELD. The Biden administration has proposed to replace the base erosion and anti-abuse tax (BEAT) with a new provision called stopping harmful inversions and ending low-tax developments (SHIELD). Pat and Jenn explain what this all means.23:37 - FDII. Pat fills us in on the proposal to repeal the deduction for foreign derived intangible income (FDII) tax, and the plan to use the resulting revenue to expand research and development investment incentives. 26:08 - The OECD framework. We discuss the proposed global minimum tax as part of the Organisation for Economic Co-operation and Development (OECD) framework and what it means for multinationals and international tax. 34:39 - Other key proposals. Pat highlights a number of other proposals affecting corporate income taxes, and Jenn provides takeaways from a financial statement perspective. The key is scenario planning - be prepared. 37:24 - What's next? It's up to Congress now. Pat and Jenn expect the increase in corporate taxes to be enacted by the end of 2021, with changes to international tax law having a longer runway.Want to learn more? Read our related PwC Tax Insight, Treasury ‘Green Book' describes Biden's tax proposals for businesses Listen to our Podcast: What global tax initiatives could mean for your company Listen to the cross-border tax talks Podcast: Explaining the explanation: Biden's GreenbookPat Brown is PwC's Washington National Tax Services co-leader. Prior to joining PwC, he spent 16 years in the private sector, including a role as the director of tax policy for a Fortune 50 company. Pat has also served in the US Treasury's Office of Tax Policy as an attorney-advisor and as Associate International Tax Counsel.Jennifer Spang is PwC's National Office income tax accounting leader specializing in tax accounting under US GAAP and IFRS. She has over 25 years of experience helping companies in a variety of industries navigate complex tax accounting matters.

 On the morning of FDII, Paul and Sammy escort Harry to an assembly of Northscouts.

Doug McHoney (PwC's US International Tax Services (ITS) Leader) holds the second post-vaccine session live at the Westminster Studios with Pat Brown (PwC WNTS Policy Co-leader) to discuss President Biden's FY 22 Budget and the much anticipated and related explanations of such proposals, also known as the Treasury Green Book. Doug and Pat cover, among other proposals: increasing the US corporate income tax rate from 21% to 28%; increasing the global intangible low-taxed income (GILTI) tax rate to 21%; removing the qualified business asset investment (QBAI) provision; repealing the deduction for foreign derived intangible income (FDII); replacing the Base Erosion and Anti-Abuse Tax (BEAT) with a Stopping Harmful Inversions and Ending Low-tax Developments (SHIELD) provision; restricting deductions of excessive interest for disproportionate borrowing in the US; the status and likelihood of the OECD's Pillars One and Two; and what companies should consider as potential tax legislation becomes more likely.

The December 2020 final foreign tax credit regulations introduced a stock-based asset apportionment methodology for all taxpayers. But given the timing of these final regulations, many taxpayers were forced to estimate their stewardship for provision purposes using the asset apportionment methodology used for interest expense. Since many taxpayers are past provision season, now is the time to consider how, under the new regulations, you can lower stewardship expenses, which may in turn improve your ETR, your foreign tax credit position and your foreign-derived intangible income (FDII) outcome.On this podcast, our international tax and transfer pricing specialists discuss:An overview of stewardship expenseThe December 2020 final foreign tax credit regulations and their approach to the treatment of stewardshipEntities to which stewardship applies  The default/residual method and the direct allocation methodMeasuring US stock basis and characterizing the stockThe seven-step approach to calculating stewardship expenseThe replay of the Tax Readiness: International tax planning post-election webcast is available here.Speakers: Elizabeth Nelson, International Tax Services PartnerAndrea Greene, International Tax Services PartnerMike Urse, International Tax Services PartnerPeter Lee, Transfer Pricing Partner

In this episode we discuss that multinationals should expect significant changes in the tax environment from both US and non-US governments and organizations like the EU and the OECD. Additionally, a likely increase in the corporate tax rate would have major impacts on the GILTI and FDII rates and calculations. This, combined with global tax measures mean that multinationals must consider their global tax structure. These next six months are crucial for data-driven analysis and planning in order to understand options and react.The replay of the Tax Readiness: International tax planning post-election webcast is available here.Speakers: Julie Allen, Washington National Tax Services Market Leader Doug McHoney, International Tax Services Co-Leader Nita Asher, US Transfer Pricing Leader Paige Hill, a Principal in PwC’s International Tax Services practice

Loren and Steve will discuss the tax proposals included in the American Jobs Plan, which are meant to fund large infrastructure investments the Biden administration plans to make. Topics addressed will include proposed modifications to the GILTI, BEAT, and FDII regimes, as well as new provisions like the minimum tax on book income and a carrot/stick approach to addressing U.S. multinationals' onshoring and offshoring activities. ********* Questions? Contact us at podcasts@milchev.com. tax break is not intended and cannot be relied on as legal advice; the content only reflects the thoughts and opinions of its hosts. tax break is a podcast about tax law, brought to you by Miller & Chevalier and hosted by Steve Dixon and Loren Ponds. We'll provide you with perspective on select tax issues that will go deeper than what the tax press covers, but not so deep that you'll have to pull out your regulations or read treatises to follow along. The aim of tax break is to focus only on the tax law issues that we find interesting. Subscribe to tax break wherever you get your podcasts.

In this episode of tax break, Steve and Loren discuss the final FDII regulations from July 2020 with Sharon Heck, Treasurer and Chief Tax Officer at Intel. They discuss several aspects of the business that have been affected by FDII, and policy discussion underscoring the importance of the provision now and going forward: Practical considerations (supply chain considerations, corollary to GILTI, impact to M&A transactions) Policy considerations (Biden tax proposals – Made in America, R&D innovation and incentivization, impact of impending R&D amortization provision) Thanks to our guest, Sharon Heck: https://www.linkedin.com/in/sharonlheck/  ********* Questions? Contact us at podcasts@milchev.com. tax break is not intended and cannot be relied on as legal advice; the content only reflects the thoughts and opinions of its hosts. tax break is a podcast about tax law, brought to you by Miller & Chevalier and hosted by Steve Dixon and Loren Ponds. We'll provide you with perspective on select tax issues that will go deeper than what the tax press covers, but not so deep that you'll have to pull out your regulations or read treatises to follow along. The aim of tax break is to focus only on the tax law issues that we find interesting. Subscribe to tax break wherever you get your podcasts.

This week, Steve and Loren discuss the final FDII regulations from July with Jeff Tebbs, International Tax Counsel at Lockheed Martin. They cover: Allocation of R&E expenses, which Treasury did not address Finalized regulations treating 250(b) as operative under 861 allocation and apportionment rules Sales of general property that primarily contain digital content How final regulations relax documentation and substantiation requirements  Thanks to our guest Jeff Tebbs for joining us: https://www.linkedin.com/in/jtebbs/  ********* Questions? Contact us at podcasts@milchev.com. tax break is not intended and cannot be relied on as legal advice; the content only reflects the thoughts and opinions of its hosts. tax break is a podcast about tax law, brought to you by Miller & Chevalier and hosted by Steve Dixon and Loren Ponds. We'll provide you with perspective on select tax issues that will go deeper than what the tax press covers, but not so deep that you'll have to pull out your regulations or read treatises to follow along. The aim of tax break is to focus only on the tax law issues that we find interesting. Subscribe to tax break wherever you get your podcasts. Apple Podcasts: https://apple.co/2WAZXPy  Spotify: https://spoti.fi/2T9wJVW  Google Podcasts: https://bit.ly/3639emF  Stitcher: https://bit.ly/2Tpals3 

Within a two-week period in July, the IRS and Treasury issued final regulations for Section 951A and Section 250, which have a significant impact on international tax. Join Charles Edge, an international tax partner with DHG, as he discusses potential tax savings for U.S. taxpayers from utilizing the now finalized GILTI inclusion and FDII deduction.

The Ernst & Young ITS Washington Dispatch brings you a monthly review of US international tax-related developments. In this edition: IRS issues final and proposed interest expense limitation regulations – Final and proposed GILTI regulations deliver few benefits, some surprises – IRS releases final regulations under Section 250 for computing FDII and GILTI deduction – IRS releases new draft partnership Schedules K-2 and K-3 for international tax reporting – US announces action against France’s DST – G20 Finance Ministers / Central Bank Governors reiterate commitment to BEPS 2.0 pillars – OECD releases new corporate tax data including CbCR statistics – OECD issues model rules for data reporting by platform operators for sellers in sharing / gig economy.  

Doug McHoney (PwC's US International Tax Services (ITS) Leader) and Ninee Dewar (a Partner in PwC's Washington National Tax Services (WNTS) ITS practice) discuss the recently-released Foreign Derived Intangible Income (FDII) final regulations under Section 250. Doug and Ninee discuss: the background of the Section 250 deduction and how the deduction interplays with both FDII and Global Intangible Low-Taxed Income (GILTI); how the final regulations compare to the March 2019 proposed regulations under Section 250, including various changes to the documentation rules and loss transactions; Ninee's advice for taxpayers to meet the substantiation requirement; the background of the 'ordering rule' and how the rule helps coordinate Sections 250, 163(j), and 172(a); the importance of remembering that the Section 250 deduction is a taxable-income deduction (particularly in light of recent changes to the Net Operating Loss rules); how the final regulations treat electronically-supplied services and advertising services; how the final regulations treat related-party sales; and various important effective dates and applicability dates for the final and proposed regulations.

In this podcast, Mike DiFronzo (PwC’s Washington National Tax Services ITS Leader), Ninee Dewar (PwC International Tax Services Partner), Kartikeya Singh (PwC Transfer Pricing Partner), and Karen Lohnes (PwC Mergers & Acquisitions Partner) discuss highlights of what the final FDII regulations cover, the new substantiation rules, deduction mechanics, FDDEI sales, FDDEI services, related party sales, and partnerships. Contacts: Mike DiFronzo, Ninee Dewar, Kartikeya Singh, Karen Lohnes

Joe Bublé and Partner Paul Dailey discuss foreign derived intangible income or FDII in this episode of Taxes in 10, brought to you by Citrin Cooperman

A review of the week's major US international tax-related news. In this edition: US Treasury sends final FDII, GILTI deduction regulations to OMB for review – OECD official says governments refocusing on BEPS.

The Nebraska Department of Revenue issued guidance addressing the state tax treatment of GILTI and FDII.

The Nebraska Department of Revenue issued guidance addressing the state tax treatment of GILTI and FDII.

* Use coupon code PODCAST25 for 25% off this webcast * Webcast URL: https://www.theknowledgegroup.org/webcasts/trends-and-developments-on-gilti-fdii-and-beps/ Join us for this Knowledge Group Trends and Developments on GILTI FDII and BEPS CLE Webinar. The international tax landscape is expected to dramatically change before 2019 ends as developing countries consider a new global tax system and as the Tax Cuts and Jobs Act (TCJA) moves closer towards full implementation. Recent developments that should give us a glimpse of the future include the final set of global intangible low-taxed income (GILTI) regulations, the newly proposed foreign-derived intangible income (FDII) rules, and the Inclusive Framework on Base Erosion and Profit Shifting (BEPS) program which aims to address “the tax challenges arising from the digitalisation of the economy.” U.S. companies should revisit their tax strategies to cope with the looming changes. Join a panel of key thought leaders and practitioners assembled by The Knowledge Group as they delve into an in-depth analysis of the current and emerging trends and developments surrounding GILTI, FDII, and BEPS enforcement. Speakers will also offer helpful insights on how to develop and implement effective strategies to mitigate risks and pitfalls and ensure compliance in this evolving regulatory climate. For any more information please click on the webcast URL at the top of this description.

In this episode of Checkpoint Presents: World of Tax, host Chris Migliaccio talks with Priya White, International Tax Manager at RSM US LLP, about the challenges in advising clients on GILTI and FDII. They cover the importance of modeling to provide client guidance, and why that’s such a big shift from the Subpart F rules.

A review of the week's major US international tax-related news. In this edition: IRS releases proposed Section 1446(f) regulations on W/H for non-publicly traded partnerships – Proposed rules on FIRPTA exception for foreign pension funds expected soon – EU comments on IRC Section 250 proposed regulations, criticizes FDII

A review of the week's major US international tax-related news. In this edition: US House Republican tax writers voice concern to President Trump about France’s DST proposal – US officials comment on future final Section 250 FDII regulations – IRS’s new APMA Functional Cost Diagnostic Model may be used in examinations in ‘appropriate’ cases – GAO issues report on FATCA – OECD Forum on Tax Administration announces ICAP 2.0

OECD holds consultation on tax challenges of digitalization, with aggressive 2020 deadline – IRS issues proposed Section 250 regulations on computing FDII and GILTI deduction – Final GILTI regulations coming by summer, PTI regs by late summer / early fall – IRS releases final FATCA regulations on compliance and verification procedures – EU comments on US Section 59A BEAT regulations – IRS APMA releases Functional Cost Diagnostic Model for certain APAs – IRS requiring TP teams to consult with APMA in certain cases – IRS releases 2018 APA results – US, India sign CbC exchange agreement – OECD releases beneficial ownership toolkit

Doug McHoney (PwC's US International Tax Services Leader) interviews Alex Voloshko (PwC’s US Value Chain Transformation Leader) and Marco Fiaccadori (PwC Transfer Pricing Principal) about the recently released Foreign Derived Intangible Income (FDII) regulations under Section 250. Among other topics, they discuss how FDII interplays with GILTI, and how the FDII proposed regulations would apply to property transactions, component manufacturing, intangibles, and services.

In this bottom line videocast, Eversheds Sutherland’s Taylor Kiessig and Katie Sint* provide key takeaways from the proposed section 250 regulations, including: calculation of FDII and the section 250 deduction types of transactions that qualify documentation rules Discover more of the latest legal news and topics discussed by our attorneys by subscribing to the Eversheds Sutherland Legal Insights Podcast Channel. *Not admitted to practice. Application submitted to the District of Columbia Bar.

In this bottom line videocast, Eversheds Sutherland’s Taylor Kiessig and Katie Sint* provide key takeaways from the proposed section 250 regulations, including: calculation of FDII and the section 250 deduction types of transactions that qualify documentation rules Discover more of the latest legal news and topics discussed by our attorneys by subscribing to the Eversheds Sutherland Legal Insights Podcast Channel. *Not admitted to practice. Application submitted to the District of Columbia Bar.

https://player.vimeo.com/video/322457804https://www.currentfederaltaxdevelopments.com/podcasts/2019/3/9/2019-03-11-199a-return-issues Look at some items causing confusion over §199A on discussion forums as returns are prepared Treasury announces changes in temporary regulations and subregulatory guidance Recipients of sexual harassment and sexual abuse settlements with confidentiality clause allowed to deduct legal fees Gambling loss triggered by impulse control problem side effect of prescribed drug not a casualty loss Proposed regulations issued for FDII and GILTI IRS no longer plans to issue regulations to bar post-retirement lump-sum

This week we talk about the following: Look at some items causing confusion over §199A on discussion forums as returns are prepared Treasury announces changes in temporary regulations and subregulatory guidance Recipients of sexual harassment and sexual abuse settlements with confidentiality clause allowed to deduct legal fees Gambling loss triggered by impulse control problem side effect of prescribed drug not a casualty loss Proposed regulations issued for FDII and GILTI IRS no longer plans to issue regulations to bar post-retirement lump-sum distributions from defined benefit plans Partnerships required to add tax basis disclosures given until March 15, 2020 to provide information to IRS Copyright 2019 Kaplan, Inc.

A review of the week's major US international tax-related news. In this edition: IRS releases Section 250 proposed regulations on determining deduction for FDII and GILTI – IRS announces hearings on proposed regulations on BEAT, hybrid mismatches – IRS APMA releases Functional Cost Diagnostic Model for APA requests – ITS updates FATCA FAQs – EY submits comments on OECD tax consultation on digitalization of the economy

A review of the week's major US international tax-related news. In this edition: OMB completed review of proposed FDII regulations – US government supports efforts to encourage countries to adopt corporate minimum tax – IRS LB&I memo requires transfer pricing issue teams to consult with APMA – IRS requesting comments on final regulations on imposition of Section 6662 accuracy-related penalty for Section 482 adjustments

A review of the week's major US international tax-related news. In this edition: US government to release proposed regulations on most TCJA international provisions by year-end; finalization by June 2019 -- IRS to step-up action on withholding tax campaigns in new year -- OECD Forum on Harmful Tax Practices to review TCJA’s FDII later this month -- US official says OECD making good progress on long-term digital tax package

Bloomberg Tax's Meg Hogan and John Bentil discuss the new IRC Section 250 deduction for foreign-derived intangible income. Jumpstart is a new podcast series from the Bloomberg Tax editorial team that explains tax law changes made by the 2017 tax reform act.

US Treasury releases proposed Section 965 regulations on repatriation transition -- IRS proposed GILTI regs under review by OMB; draft GILTI and FDII forms released -- IRS announces upgrades to FATCA Registration System – US Tax Court holds upstream loan between CFCs was bona fide debt, later transfer of proceeds to US shareholders nontaxable return of capital - DC Circuit rejects per se bar on bearer shares under Section 883 income exclusion for international shipping and aircraft corporations - Ninth Circuit withdraws opinion reversing Tax Court in Altera — US Tax Court rules Section 1446 W/H tax liability is a partnership item -- Eighth Circuit vacates Tax Court opinion in Medtronic, remands to Tax Court for further consideration -- OECD releases fourth batch of peer review reports on Action 14

A review of the week's major US international tax-related news. In this edition: US Treasury sends TCJA’s global intangible low taxed income (GILTI) regulations to OMB for review – IRS issues draft forms for GILTI, foreign derived intangible income (FDII) provisions

Ray Polantz, head of Cohen & Company’s International Practice, and Tax Partner Maura Corrigan discuss why these two international provisions are game changers for U.S. multi-national taxpayers and the 180-degree turnaround to how foreign earnings are taxed.

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A review of the week's major US international tax-related news. In this edition: US government issues more repatriation transition guidance in Rev. Proc. 2018-17 – Treasury officials offer insights on future international TCJA guidance – US to defend TCJA’s FDII provision as WTO-compliant – IRS taking leadership role in OECD’s International Compliance Assurance Program -- OECD released more BEPS Action 13 CbC reporting guidance

We’re back to help you cut through the static of the Tax Cuts and Jobs Act with the second in a series of episodes that breaks down what the new tax law means for you and your business. BKD’s Chris Clifton covers the international provisions of the new tax law and explains how they fit into the larger world of international taxation. Some of the important areas covered in this episode include: Shift to a territorial system @ 2:28 Deemed repatriation @ 4:17 Global intangible low-taxed income (GILTI) @ 10:27 Base erosion anti-abuse tax (BEAT) @ 14:08 Limitation on deduction for interest expense @ 18:50 Areas where additional guidance is needed @ 22:25 Foreign derived intangible income (FDII) @ 29:27 International considerations for converting an S corp to a C corp @ 36:42 Key takeaways @ 40:25 BIO FOR GUEST Chris Clifton is a managing director in BKD’s International Tax Services division. His focus is on international tax planning and compliance for domestic, foreign and multinational corporations in areas such as foreign tax credits, subpart F, withholding taxes and income tax treaties.

We're back to help you cut through the static of the Tax Cuts and Jobs Act with the second in a series of episodes that breaks down what the new tax law means for you and your business. BKD's Chris Clifton covers the international provisions of the new tax law and explains how they fit into the larger world of international taxation. Some of the important areas covered in this episode include: Shift to a territorial system @ 2:28 Deemed repatriation @ 4:17 Global intangible low-taxed income (GILTI) @ 10:27 Base erosion anti-abuse tax (BEAT) @ 14:08 Limitation on deduction for interest expense @ 18:50 Areas where additional guidance is needed @ 22:25 Foreign derived intangible income (FDII) @ 29:27 International considerations for converting an S corp to a C corp @ 36:42 Key takeaways @ 40:25 BIO FOR GUEST Chris Clifton is a managing director in BKD's International Tax Services division. His focus is on international tax planning and compliance for domestic, foreign and multinational corporations in areas such as foreign tax credits, subpart F, withholding taxes and income tax treaties.