Last week, the Supreme Court upheld the 2017 tax rules on foreign income in the Moore v. U.S. case. Danielle Rolfes, Partner-in-Charge of Washington National Tax, states that this decision provides additional clarity on the taxation of foreign subsidiaries of US companies. Read more here: https://lnkd.in/eJRiQufM
KPMG US Tax ’s Post
More Relevant Posts
-
Interesting and timely analysis of the Moore v. United States case currently pending before the US Supreme Court on the "quadrillion-dollar" question of whether a one-time levy on “unrealized” gains by a US citizen in a foreign corporation under a provision of the 2017 Tax Act is constitutional and within Congress’s 16th Amendment power to tax income. #taxes #internationaltaxation
To view or add a comment, sign in
-
The U.S. Supreme Court is reviewing the case of 𝘔𝘰𝘰𝘳𝘦 𝘷. 𝘜𝘯𝘪𝘵𝘦𝘥 𝘚𝘵𝘢𝘵𝘦𝘴, which challenges the constitutionality of the transition tax on untaxed foreign earnings imposed by the Tax Cuts and Jobs Act (TCJA). Our Alvarez & Marsal #Tax team discusses the substantial tax refunds and potential questions raised about other tax regimes if this provision were to be invalidated. They further recommend that taxpayers evaluate the implications of the case, while also protecting their rights to claim refunds until the case is decided. Read their full insights here: https://bit.ly/3DvfAwy Alan Cathcart Kevin M. Jacobs Emily Leebron Foster Kenneth Brewer Andrew Johnson Albert Liguori Lee Zimet Brendan Sinnott #Taxes #TaxLaw #TransitionTax #Taxpayers
To view or add a comment, sign in
-
-
In this #GMSFlashAlert, #KPMG U.S. reports on the IRS announcing temporary relief for taxpayers determining whether a non-U.S. tax is eligible for foreign tax credit under U.S. tax law for taxes paid or accrued in tax years 2022 and 2023.#KPMGWNT
GMS Flash Alert: IRS Provides Temporary Foreign Tax Credit Relief in the U.S.
kpmg.voicestorm.com
To view or add a comment, sign in
-
On the cover of Tax Notes International: Kim Blanchard explains how the rules of pillar 2 are based on assumptions derived from territorial tax systems that cannot be reconciled with U.S. tax rules that impose a separate shareholder-level tax on corporate earnings under a residence-based system, and she makes the case that because the United States has always taxed the worldwide income of its residents, the application of pillar 2 to U.S. taxpayers is unnecessary and can result in unintended double taxation. #internationaltaxation #tax #taxes #GILTI #FTC #CFC
Can U.S. Worldwide Taxation and Pillar 2's Minimum Tax Peacefully Coexist? | Tax Notes
taxnotes.com
To view or add a comment, sign in
-
Insights from the US Supreme Court's ruling on foreign income tax: How this decision shapes corporate tax compliance and impacts economic policies worldwide. https://hubs.la/Q02CHJs90
Supreme Court upholds foreign income tax on US businesses - InvestmentNews
https://www.investmentnews.com
To view or add a comment, sign in
-
In this #GMSFlashAlert, #KPMG U.S. reports on the IRS announcing temporary relief for taxpayers determining whether a non-U.S. tax is eligible for foreign tax credit under U.S. tax law for taxes paid or accrued in tax years 2022 and 2023.#KPMGWNT
GMS Flash Alert: IRS Provides Temporary Foreign Tax Credit Relief in the U.S.
kpmg.voicestorm.com
To view or add a comment, sign in
-
In this #GMSFlashAlert, #KPMG U.S. reports on the IRS announcing temporary relief for taxpayers determining whether a non-U.S. tax is eligible for foreign tax credit under U.S. tax law for taxes paid or accrued in tax years 2022 and 2023.#KPMGWNT
GMS Flash Alert: IRS Provides Temporary Foreign Tax Credit Relief in the U.S.
kpmg.voicestorm.com
To view or add a comment, sign in
-
The Moore Court Case went all the way to the Supreme Court which ruled in favor of sustaining the mandatory repatriation tax. You can read the article by our International Tax Practice leader Laura Tshilumba, CPA, HMCC where she explains the history of this case and what it means for certain U.S. taxpayers. #InternationalTax #MooreCourtCase #RepatriationTax https://lnkd.in/gS2bZF3w
To view or add a comment, sign in
-
-
The IRS has new guidance on foreign tax credits. In this installment of U.S. Tax Review, tax partners Larissa Neumann, Julia Ushakova-Stein, and Mike Knobler review new guidance on foreign tax credits and the corporate AMT, partnership regulations, recent case law developments, the delay of 1099-K reporting, and comments on section 174 and pillar 1. Read more: https://bit.ly/48JHLG5 #TaxLaw #IRS
U.S. Tax Review: Foreign Tax Credits, CFCs and The Corporate AMT,...
To view or add a comment, sign in