The Chamberlain Hrdlicka Business and International Tax Blog provides updates, developments, and insights on business and international tax.
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Sorting Out the Parallel Universes of Subpart F and GILTI Income Inclusions: The Unintended Collision With Respect to Deemed Sale of Controlled Foreign Corporation Stock[1]
By Jerald David August
The Tax Cuts and Jobs Act of 2017, P.L. 115-87 (TCJA), [2] enacted into law on December 22, 2017, introduced numerous reforms to international taxation which changes have already had a profound impact on tax planning for multinational business enterprises (MNEs) as well as domestic businesses engaged in foreign business ventures or investments.[3] The most significant reform enacted ...
Final Regulations Under 20% Qualified Business Deduction Issued by Treasury In Time For Filing 2018 Tax Returns
Revenue Procedure to Set Forth Rental Real Estate as a Qualified Business to be Issued Shortly
By: Jerry August
In an article published on Dec. 04, 2018, in Tax Analysts, Jerry August provides comments on planning strategies for U.S. companies engaging in real estate and licensing transactions overseas. Jerry says, “Real estate deals are often heavily leveraged, so it’s common to see a special purpose vehicle (SPV) formed to borrow money. That SPV is owned by a joint venture with the U.S. taxpayer, either as a general partner or a limited partner, as well as partners from other countries.”
Subscribers to Tax Notes may view the full article here.