- US multinational corporations doing business in foreign countries (and foreign based multinational corporations doing business inside the US or foreign countries other than their own) are typically subject to the domestic tax laws of the countries where they engaged in business activities.
- Baker Tilly international tax specialists, Ian Halligan and Lynette Stolarzyk, analyze the Sec. 962 election to possibly defer tax until a later actual repatriation of corresponding Sec. 962 E&P.
- Baker Tilly international tax specialist, Mayra Pena and Richard Shapland, reassess the tax benefits of IC-DISCs due to tax rate differential changes under tax reform in the AICPA Tax Adviser.
- Tax reform dramatically changed the way U.S. multinationals are taxed and how U.S. multinationals operate abroad thanks to a new hybrid territorial tax system, base erosion measures and a repatriation tax.
- The September Tax Reform Progress Report discusses the three bills that comprise Tax Reform 2.0, new proposed regulations for determining a CFC’s GILTI income, elimination of a state and local tax workaround and where we are with TCJA-related regulations and guidance.