Employee Benefits Blog

Posts tagged International tax

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GILTI as Charged

(A new tax on foreign earnings – explained in plain English)

Earlier this year, we provided a summary article entitled International Tax Provisions of the Tax Cuts and Jobs Act. As its name implies, it provides an overview of a number of the features in the December 2017’s Tax Cuts and Jobs Act (the “Act”) that affected foreign activity. We followed that with a more detailed article addressing the most urgent international tax aspect in the Act: The One-time Deemed Dividend Repatriation Tax on Deferred Foreign Earnings that was due (in part) in April 2018.

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Treasury Department Releases Proposed Regulations Related to Section 965 Today

Proposed regulations related to Internal Revenue Code Section 965 were released today by the Treasury Department, providing additional guidance on the new repatriation tax on certain foreign earnings that was imposed by December 2017’s Tax Cuts and Jobs Act.

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One-Time Deemed Dividend Repatriation Tax on Deferred Foreign Earnings

The recently passed tax act uses the mechanics of subpart F to impose a one-time “toll tax” on the undistributed, non-previously taxed, post -1986 foreign earnings and profits (E&P) of certain U.S.-owned corporations as part of the transition to a new partial territorial tax regime.

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International Tax Provisions of the Tax Cuts and Jobs Act

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The Tax Cuts and Jobs Act (“TCJA”) recently passed by Congress and the President represents a true game changer for U.S. corporations, foreign corporations doing business in the U.S., and individuals and pass through entities with international investments and transactions. This article highlights international tax implications of the new law.