GILTI or not GILTI?

Additional regulations for Global Intangible Low-Taxed Income (“GILTI”) were released on June 14, 2019.  Taxpayers were relieved to find two favorable adjustments: Proposed GILTI high-tax exclusion Final guidance on how to calculate GILTI for partnerships High-Tax Exclusion GILTI was put into place to tax the intangible earnings of companies and

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Tax Strategies for Manufacturers and Distributors

On February 13, 2018, Highlights of the tax reform were presented by members of the Barnes Dennig Tax team to local manufacturing and distribution business leaders. With over 1,000 pages of tax reform issued to date and additional guidance continuing to be released, it is an exciting time in the

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Transfer Pricing Compliance Issues Targeted in new IRS Campaign

The IRS has launched an initiative under the Large Business and International (LB&I) Division to audit U. S. subsidiaries of foreign multinational corporations which operated as distributors in the US for product manufactured by the related party for sale to U.S. customers.  The LB&I published a Practice Transaction Unit in

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