Payroll Implications of the CARES Act for Manufacturers

Estimated at over $2.2 trillion, the Coronavirus Aid, Relief, and Economic Security (CARES) Act of 2020 is the single most expensive legislation in U.S. history. The CARES act was implemented rather quickly when it was signed into law by President Trump in March of 2020. It was intended to provide

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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 Ins and Outs of Cross-Border Taxation

Understanding Outbound Transactions Cross-border taxation can be divided into various categories based on the type of the transaction, with the highest division being “Inbound vs. Outbound.” Inbound refers to non-U.S. persons (and in this case, “persons” meaning both individuals as well as entities) having U.S. income. Outbound is the opposite,

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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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New Rules to Take Deduction on Foreign Income

Proposed regulations on Foreign Derived Intangible Income (FDII) were released earlier in 2019. One of the main highlights to these proposed regulations was the new strict documentation rules. For a brief recap on the release, and to learn when a C-corporation can benefit from the FDII deduction due to revenue

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