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Advising International Business Ventures: “Tested Income” under GILTI

In International Tax, Tax Reform by Jason FreemanLeave a Comment

Freeman Law frequently advises international business ventures.  International operations often give rise to unique (and sometimes unanticipated) compliance obligations and complex reporting requirements. Recent tax reform rules and regulations have imposed a number of new requirements.  The IRS and Treasury Department have elaborated on these new rules through proposed regulations and other guidance.  This post provides a short introduction to the …

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U.S. Shareholder: Changes Under the TCJA

In International Tax, Tax Reform by Jason FreemanLeave a Comment

Freeman Law frequently advises international business ventures. International operations often give rise to unique (and sometimes unanticipated) compliance obligations and complex reporting requirements. Recent tax reform rules and regulations have imposed a number of new requirements.  The IRS and Treasury Department have elaborated on these new rules through proposed regulations and other guidance.  This post provides a short introduction to the …

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Advising International Business Ventures: Tax Reform’s Section 245A Participation Exemption Regime

In International Tax, Tax Reform by Jason FreemanLeave a Comment

Freeman Law frequently advises international business ventures. International operations often give rise to unique (and sometimes unanticipated) compliance obligations and complex reporting requirements. Recent tax reform rules and regulations have imposed a number of new requirements.  The IRS and Treasury Department have elaborated on these new rules through proposed regulations and other guidance.  This post focuses on, and provides a short …

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Second Installment: Advising International Business Ventures: Tax Reform’s “Transition” Tax

In International Tax, Tax Reform by Jason FreemanLeave a Comment

Freeman Law frequently advises international business ventures. International operations often give rise to unique (and sometimes unanticipated) compliance obligations and complex reporting requirements. Recent tax reform rules and regulations have imposed a number of new requirements.  The IRS and Treasury Department have elaborated on these new rules through proposed regulations and other guidance.  This post focuses on, and provides a second …

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Advising International Business Ventures: Tax Reform’s “Transition” Tax

In International Tax, Tax Reform by Jason FreemanLeave a Comment

Freeman Law frequently advises international business ventures. International operations often give rise to unique (and sometimes unanticipated) compliance obligations and complex reporting requirements. Recent tax reform rules and regulations have imposed a number of new requirements.  The IRS and Treasury Department have elaborated on these new rules through proposed regulations and other guidance.  This post focuses on, and provides a short …

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Advising International Business Ventures: Tax Reform’s New GILTI Tax

In GILTI, International Tax, Tax Reform by Jason FreemanLeave a Comment

Freeman Law frequently advises international business ventures. International operations often give rise to unique (and sometimes unanticipated) compliance obligations and complex reporting requirements. Recent tax reform rules and regulations have imposed a number of new requirements.  The IRS and Treasury Department have elaborated on these new rules through proposed regulations and other guidance.  This post focuses on, and provides a short …

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Advising International Business Ventures: Tax Reform and a Quasi-Territorial Tax System

In CFC, International Tax, Participation Exemption, Tax Reform by Jason FreemanLeave a Comment

The Tax Cuts and Jobs Act (“TCJA”) led a shift from a “worldwide” tax system towards a territorial tax system—more accurately, a “quasi”-territorial tax system.  The TCJA accomplished this through several major reforms.  First, it enacted a “toll charge,” or transition tax—a one-time tax on the deemed repatriation of earnings held offshore. In exchange, it implemented a “Participation Exemption System” that …

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A Practical Roadmap Through Section 199A

In 199A, Tax Reform by Jason Freeman3 Comments

Perhaps no other provision of the Tax Cuts and Jobs Act of 2017 has given rise to more speculation, debate, and consternation than new Section 199A. The complex maze that is Section 199A introduces a set of rules and formulas that determine when a taxpayer qualifies to deduct 20 percent of certain income from “pass-through” trades or businesses. The provision, …

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New Changes Are Coming to Partnership Withholding

In International Tax, Offshore Tax, Partnership Tax, Tax Reform by freemanlawdevLeave a Comment

Section 13501 of the Tax Cuts and Jobs Act created a withholding requirement on the transfer of non-publicly traded partnership interests[1] by amending §§864(c) and 1446 of the Internal Revenue Code.[2]   Section 864(c)(8) provides that gain or loss from the sale, exchange, or other disposition of a partnership interest by a nonresident alien or foreign corporation is effectively connected with …

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The IRS Announces New “Compliance Campaigns:” Unreported Virtual Currency, S-Corporation Compliance, and International Tax Enforcement Are Top Priorities

In International Tax, S Corporations, Tax Reform by Jason FreemanLeave a Comment

The IRS recently announced five new “compliance campaigns”—areas where it intends to focus additional resources and enforcement efforts.  It comes as no surprise that unreported virtual currency, S-corporation dividends, and international tax are at the core of its focus.  The five compliance campaigns are:   S-corporation Distributions Virtual Currency Restoration of AMT Credit Carryforwards Repatriation through Foreign Triangular Reorganizations Section …