Andrew Solomon and Donald L. Korb (Sullivan & Cromwell) discuss the recent US Treasury regulations on two of the US tax reform’s most significant provisions.
In our last article (see ‘US tax reform: inbound investment’ Tax Journal 15 February 2019) we discussed two of the most significant sets of proposed regulations issued pursuant to the Tax Cuts and Jobs Act 2017 (‘the Act’): those concerning the section 163(j) interest deduction limitation and base erosion and anti-abuse tax (BEAT). Those two sets of proposed regulations primarily affect investment into the US. This article will focus on proposed regulations that primarily affect outbound investment by US multinationals. These proposed regulations concern two important international changes effected by the Act:
the provisions requiring the current taxation of US shareholders on their share of the global intangible low-taxed income (GILTI) of controlled foreign corporations (CFCs) of which they are shareholders (whether or...
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Andrew Solomon and Donald L. Korb (Sullivan & Cromwell) discuss the recent US Treasury regulations on two of the US tax reform’s most significant provisions.
In our last article (see ‘US tax reform: inbound investment’ Tax Journal 15 February 2019) we discussed two of the most significant sets of proposed regulations issued pursuant to the Tax Cuts and Jobs Act 2017 (‘the Act’): those concerning the section 163(j) interest deduction limitation and base erosion and anti-abuse tax (BEAT). Those two sets of proposed regulations primarily affect investment into the US. This article will focus on proposed regulations that primarily affect outbound investment by US multinationals. These proposed regulations concern two important international changes effected by the Act:
the provisions requiring the current taxation of US shareholders on their share of the global intangible low-taxed income (GILTI) of controlled foreign corporations (CFCs) of which they are shareholders (whether or...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
