Section 250 Final Regulations Roadmap

Final regulations for Section 250 of the Tax Cuts and Jobs Act have been released to address the potential harm GILTI presents to the competitive business position of domestic corporations. Our comprehensive report, Section 250 Final Regulations Roadmap, will guide your organization and clients in 250 deductions and related definitions for taxable years beginning January 1, 2021.

Section 245A Regulations Roadmap

The Section 245A Regulations Roadmap highlights key takeaways from the temporary and proposed regulations released thus far.

Highlights of the §199A Rules for Cooperatives and Their Patrons

Treasury and the IRS published proposed regulations (REG-118425-18, 84 Fed. Reg. 28,668 (Jun. 19, 2019)),which provide guidance for cooperatives and their patrons regarding the deduction for qualified business income (QBI) under I.R.C. §199A(a).

Section 250 Proposed Regulations Roadmap

In an effort to combat possible indefinite deferral of U.S. taxation with respect to active foreign business income, the 2017 tax act (Pub. L. No. 115-97) enacted §951A, which requires each U.S. shareholder of a controlled foreign corporation (CFC) to include its “global intangible low-taxed income” (GILTI) for the taxable year in gross income.

Section 965: Understanding the Transition Tax

Section §965 imposes a transition tax on certain deferred foreign income of U.S. shareholders of a so-called “deferred foreign income corporation” in the last taxable year of that corporation which begins before January 1, 2018.

Section 199A Regulations Roadmap

In January 2019, Treasury and the IRS released final regulations, T.D. XXXX, RIN 1545-BO71, which finalize the August 2018 proposed regulations with some modifications.

Section 163(j) Proposed Regulations Roadmap

The 2017 tax act (Pub. L. No. 115-97) significantly changed the deductibility of business interest expense for tax years beginning after December 31, 2017.