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Business and International Tax Developments

The Chamberlain Hrdlicka Business and International Tax Developments Blawg provides updates on business and international tax.

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Posts from August 2019.

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 ...