FDII Regulations – Another Win for the Taxpayers?

The final IRC Section 250 regulations were released on July 9, 2020. Section 250 provides deductions for Global Intangible Low-Taxed Income (“GILTI”) and Foreign-Derived Intangible Income (FDII). The final regulations are viewed as taxpayer-favorable as they reduced some documentation requirements and provided more flexibility to substantiate the deductions. In 2017,

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The GILTI Verdict Is In

Retroactive and Future High-Tax Exceptions Available New regulations released by the Treasury Department on July 21, 2020 have confirmed inclusion of a high-tax exception to avoid global intangible low-taxed income (GILTI). Released under IRC Section 951A and the temporary regulations under section 954, these regulations have been anxiously awaited since

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IRS Provides Additional Filing Relief to Taxpayers

In March, The Internal Revenue Service (IRS) announced the extension of filing and payment of federal taxes due on April 15, 2020, to July 15, 2020. This extension allows for no late filing penalties or interest to be assessed.  Notice 2020-23 was issued late last week to provide additional tax

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Do Tariffs Leave You Feeling “Taxed”?

Barnes Dennig hosted its second international roundtable on October 30, 2019 to gather companies together to discuss how the tariffs have impacted them and how to reduce the impact tariffs have had on their companies. David Schwartz, practice group leader of international trade at Thompson Hine, joined the discussion

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