In 2017, certain taxpayers were subject to a one-time tax on earnings in controlled foreign corporations under Section 965, also known as the transition tax. Since this was a newly created, [...]
As we have detailed many times, the transition tax and GILTI were two tax laws that were not designed for individual taxpayers. Therefore, much of the guidance and regulations have little impact [...]
Despite claims of attempting to simplify compliance, in recent years, forms and compliance for international reporting has become much more detailed and complicated. In keeping with this theme, [...]
Following up on our blog “GILTI and the Transition Tax: How, Why and Moving Forward,” HMLLP Partner Josh Maxwell will be presenting on these topics in collaboration with AMCHAM [...]
In this extended blog we explain the policy problems with these new tax laws, how to address them, and offer some suggestions for the future. GILTI and the Transition Tax: Why, How and Moving Forward
Once it enters into force, the USMCA will replace NAFTA. Since many U.S. tax treaties make reference to NAFTA, it was unknown if this would cause any issues with these provisions, and despite a [...]
Between the Tax Cuts and Jobs Act and the coronavirus, there have been many unique tax situations lately. It was only a matter of time before these started to interact and cause problems. As [...]
Many U.S. international tax laws are determined based on time spent in or out of the U.S., as well as what type of activities and the amount of activities performed in the U.S. With the [...]
Today, IRS Notice 2020-23 widely expanded the coronavirus extensions and clarified some very key issues. In general, most, if not all, tax returns, payments, and elections that are due from [...]
