Tag Archives: #cordascocpa

Tax Reform Series 49 – Related Party Payments Involving Hybrid Entities or Hybrid Transactions

Plain Language of Change: The Act includes anti-hybrid rules denying deductions for any disqualified related-party amount paid or accrued pursuant to a hybrid transaction or by, or to, a hybrid entity, for example, interest and royalties paid to related foreign … Continue reading

Posted in Blog | Tagged , , | Comments Off on Tax Reform Series 49 – Related Party Payments Involving Hybrid Entities or Hybrid Transactions

Tax Reform Series 48 – Limits on Income Shifting Through Intangible Property Transfers

Plain Language of Change: Changes the definition of intangible property Workforce in place, goodwill (both foreign and domestic) and going concern value are intangible property Codifies use of the realistic alternative principles to determine valuation with respect to intangible property … Continue reading

Posted in Blog | Tagged , , | Comments Off on Tax Reform Series 48 – Limits on Income Shifting Through Intangible Property Transfers

Tax Reform Series 47 – Base Erosion and Anti-Abuse Tax

Plain Language of Change: The Act provides for a base erosion and anti-abuse tax (BEAT) which imposes a new alternative minimum tax at a rate of 10 percent for certain large multinational corporations The BEAT applies to domestic corporations that … Continue reading

Posted in Blog | Tagged , , | Comments Off on Tax Reform Series 47 – Base Erosion and Anti-Abuse Tax

Tax Reform Series 46 – Other Subpart F Changes

Plain Language of Change: Repeals of section 955, which required an inclusion of qualified foreign base company shipping operations. Repeals foreign base company oil related income as a category of foreign base company income, i.e., subpart F income Modifies the … Continue reading

Posted in Blog | Tagged , , | Comments Off on Tax Reform Series 46 – Other Subpart F Changes

Tax Reform Series 45 – Foreign High Return Amounts of U.S. Shareholders of Controlled Foreign Corporations (CFCs)

Plain Language of Change: The Act adds section 951A to the Internal Revenue Code which would require a U.S. shareholder of a CFC to include in income its GILTI in a manner similar to subpart F income In general, GILTI … Continue reading

Posted in Blog | Tagged , , | Comments Off on Tax Reform Series 45 – Foreign High Return Amounts of U.S. Shareholders of Controlled Foreign Corporations (CFCs)

Tax Reform Series 44 – Recapture of Overall Domestic Losses

Plain Language of Change: The Act increases the overall domestic loss (ODL) allowance by providing an election to increase the percentage (but not greater than 100 percent) of domestic taxable income offset by any pre-2018 unused overall domestic loss and … Continue reading

Posted in Blog | Tagged , , | Comments Off on Tax Reform Series 44 – Recapture of Overall Domestic Losses

Tax Reform Series 43 – Source of Income Rules for Cross-Border Inventory Sales

Plain Language of Change: The Act modifies the source of income from sales of inventory and now the source is determined solely on the basis of production activities Gains, profits and income from the sale or exchange of inventory property … Continue reading

Posted in Blog | Tagged , , | Comments Off on Tax Reform Series 43 – Source of Income Rules for Cross-Border Inventory Sales

Tax Reform Series 42 – Foreign Tax Credit Limitation Baskets

Plain Language of Change: The Act creates a new FTC limitation basket for foreign branch income Foreign branch income is the business profits of a U.S. person which are attributable to one or more qualified business units (QBUs) in one … Continue reading

Posted in Blog | Tagged , , | Comments Off on Tax Reform Series 42 – Foreign Tax Credit Limitation Baskets

ALERT! Significant tax savings for Georgia, South Carolina and Florida Residence!

With the passage of the Tax Cuts and Jobs Act in December, 2017, Congress made a significant change to the casualty loss rule for the 2017 tax filing year. Her is what they did: The original rule limited the amount … Continue reading

Posted in Blog | Tagged , , | Comments Off on ALERT! Significant tax savings for Georgia, South Carolina and Florida Residence!

Tax Reform Series 41 – Deemed-Paid Foreign Tax Credit

Plain Language of Change: The Act repeals section 902 indirect foreign tax credits (i.e., the deemed paid credit) with respect to dividends received by a domestic corporation that owns 10 percent or more of the voting stock of a foreign … Continue reading

Posted in Blog | Tagged , , | Comments Off on Tax Reform Series 41 – Deemed-Paid Foreign Tax Credit