The IRS issued an additional regulation package on the global intangible low-taxed income (GILTI) provision, Sec. 951A, which was added by the law known as the Tax Cuts and Jobs Act, P.L. 115-97, and requires 10% U.S. shareholders of controlled foreign corporations (CFCs) to include in their gross income their share of the CFC's GILTI for that tax year (the inclusion amount).
The provision applies to tax years of foreign corporations beginning after Dec. 31, 2017, and to the U.S. shareholders' tax years within which the foreign corporations' tax years end. The IRS issued final regulations on Sec. 951A in June 2019 (T.D. 9866).
Not to change the topic here:
International Tax Manager / Sr. Manager - Cloudflare | Built In Austin
At Cloudflare, we have our eyes set on an ambitious goal: to help build a better Internet. Today the company runs one of the world's largest networks that powers trillions of requests per month. Cloudflare protects and accelerates any Internet application online without adding hardware, installing software, or changing a line of code. Internet properties powered by Cloudflare have all web traffic routed through its intelligent global network, which gets smarter with every request.
We realize people do not fit into neat boxes. We are looking for curious and empathetic individuals who are committed to developing themselves and learning new skills, and we are ready to help you do that. We cannot complete our mission without building a diverse and inclusive team. We hire the best people based on an evaluation of their potential and support them throughout their time at Cloudflare. Come join us!
Corporate Political Donations Undermine Pledges - The New York Times
Corporate leaders increasingly outspoken on some important issues, but there is a contradiction between their words today and the role they played in creating the moment we find ourselves in, Andrew argues in his latest column .
Companies have funded political efforts antithetical to their public stances , according to the Center for Political Accountability. The nonpartisan organization analyzed donations over the past decade to six state-level political associations known as "527s," named after a section of the tax code. Public companies were the biggest donors to the groups supporting governors, state attorneys general and local lawmakers.
FirstEnergy Corp. Statement on HB 6 Investigation | Business | valdostadailytimes.com
AKRON, Ohio, July 21, 2020 /PRNewswire/ -- FirstEnergy Corp. (NYSE: FE) today issued the following statement:
This afternoon, FirstEnergy Corp. (NYSE: FE) received subpoenas in connection with the investigation surrounding Ohio House Bill 6. We are reviewing the details of the investigation and we intend to fully cooperate.
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Many things are taking place:
Evaluating the tax implications of M&A activity in Mexico | International Tax Review
It is important when merging or acquiring shares or assets of a Mexican company that several methods are discussed and the varied tax consequences for each option are considered. For instance, if the acquisition of a target company is structured as a stock deal, the purchasing entity could benefit from existing tax concessions by not being subject to a value-added tax (VAT).
While this only represents two key major merger and acquisition (M&A) avenues, this article explores the varied tax implications of this and several other acquisition strategies in Mexico.
Protecting Nonprofit Whistleblowers
To maintain tax-exempt status, non-profits must not run afoul of IRS rules , including the following prohibitions:
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The TFA protects a broad range of disclosures about potential violations of IRS rules or tax fraud. It protects not only disclosures to the IRS but also internal disclosures, including an employee's disclosure to a supervisor or "any other person working for the employer who has the authority to investigate, discover, or terminate misconduct." In particular, TFA protected conduct includes:
Teradyne Reports Second Quarter 2020 Results Nasdaq:TER
NORTH READING, Mass., July 21, 2020 (GLOBE NEWSWIRE) -- Teradyne, Inc. (NASDAQ: TER) reported revenue of $839 million for the second quarter of 2020 of which $659 million was in Semiconductor Test, $72 million in System Test, $49 million in Wireless Test and $59 million in Industrial Automation (IA). GAAP net income for the second quarter was $188.9 million or $1.05 per diluted share.
"Stronger than expected System on a Chip (SOC) test shipments driven by accelerated demand for mobility-related test capacity, combined with success in navigating supply constraints, led to revenue and profits above the high end of our guidance range in the second quarter," said CEO and President Mark Jagiela. "Industrial Automation sales, while down from the year ago period due to the global slowdown in business activity, improved monthly through the quarter.
INSIGHT: Kenya—Taxation of the Digital Economy
In an effort to generate revenue, Kenya has introduced measures to tax the digital economy. Lynnet Mwithi of Taxwise Africa Consulting LLP looks at the recent provisions in the Finance Act 2020 intended to provide guidance and clarity on the measures, and considers their effects for business.
In 2019, Kenya introduced tax measures to tax the digital economy. Like most jurisdictions, the tax was set to widen the tax base and generate additional revenues, as the income from the digital economy went untaxed due to the nature of the businesses involved. Following the amendments made in 2019, the National Treasury is set to release regulations on mechanisms of the digital tax in 2020.
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