Proposed Foreign Tax Credit Regulations Reassure Taxpayers of Creditability of Certain Foreign Income Taxes

Small map globe on top of a blank check

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 More

GILTI 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 More

U.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 More