The Internal Revenue Service issued proposed regulations under section 250 of the Internal Revenue Code, which offers domestic corporations deductions for foreign-derived intangible income (FDII) and global intangible low-taxed income. Section 250, as well as section 951A dealing with global intangible low-taxed income, was added by the 2017 Tax Cuts and Jobs Act (TCJA). These…
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Individuals Who Need Their Passports for Imminent Travel Should Promptly Resolve Their IRS Tax Debts
The Internal Revenue Service on February 27, 2019 reiterated its warning thattaxpayers may not be able to renew a current passport or obtain a new passport if they owe federal taxes. To avoid delays in travel plans, taxpayers need to take prompt action to resolve their tax issues. In January of last year, the IRS began…
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IRS Payment Plans
For the 2019 filing season, the IRS projects that more taxpayers than ever will file and owe. Many will be able to pay – but a lot of them will need to make other arrangements because they can’t pay their full tax bills to the IRS. When taxpayers can’t pay their tax bills, they have…
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CFC Partner's E&P is Increased by Domestic Partnership's Section 951 (a) Income Inclusions
The Tax Court has concluded that for the years at issue (2007 - 2010), the earnings and profits (E&P) of the upper tier controlled foreign corporation (CFC) partner of a domestic partnership had to be increased as a result of the partnership's Code Sec. 951(a) income inclusions. (Eaton Corporation and Subsidiaries, (2019) 152 TC No.…
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