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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.
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).
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 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.