Brexit | Has the Drama Finally Subsided?

The United Kingdom (UK) officially left the European Union (EU) on January 31, 2020, in the midst of an extended period of confusion, back-and-forth negotiations and unanswered questions for many businesses and individuals that work and live in the area. With an 11-month transition plan that ended on December 31,

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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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