Posts by Jed Rogers
Proposed Foreign Tax Credit Regulations Reassure Taxpayers of Creditability of Certain Foreign Income Taxes
By: Jed Rogers, International Tax Partner; Julia Brent, Senior Tax Associate At a glance Schedule a consultation today The full story: The Final Regulations fundamentally modified and raised concerns among taxpayers that long-standing foreign income taxes may not be creditable. To summarize, the Final Regulations require satisfaction of a net gain requirement, which includes tests…
Read MoreFinal FTC Regulations: Significant Changes to the Creditability of Foreign Income Taxes
By: Jed Rogers; Tamara Fusillo At a glance Schedule a consultation today The full story: The final regulations on foreign tax credits fundamentally modify the rules for determining the creditability of foreign tax. For creditability, a foreign income tax must satisfy the net gain requirement, which includes tests to establish realization, gross receipts, and cost…
Read MoreGILTI Planning for Closely Held Companies
At a glance The main takeaway: While more foreign income is now subject to current U.S. federal income tax after the 2017 tax reform bill, there are certain actions that individual U.S. shareholders may be able to take to minimize their exposure under the global intangible low-taxed income (GILTI) provision. Impact on taxpayers: GILTI requires…
Read MoreU.S. Tax Planning Opportunities for Bona Fide Residents of Puerto Rico
At a glance: Schedule a consultation today! The full story: Over the years, the Puerto Rican government has created several tax incentives and credits to make Puerto Rico a destination for economic development and investment. In this article, we’ll explore the tax planning opportunities available to taxpayers who become “bona fide residents” of Puerto Rico,…
Read MoreThe OECD’s Two-Pillar Solution Poses Big Tax Changes for International Businesses. Will You Be Affected?
At a glance Schedule a consultation with our International Tax team today and start the conversation. The full story: Multinational businesses, prepare for big tax changes on the horizon over the next two years. Last fall, the OECD announced that qualifying businesses with a foreign presence will be subject to a 15% minimum tax rate…
Read More