The U.S. Treasury Department and the IRS have released final regulations (2020 Final Regulations) allowing certain domestic shareholders of a “controlled foreign corporation” (CFC) to elect under a high-tax exception to opt out of the tax imposed on the CFC’s “global intangible low-taxed income” (GILTI).
The 2020 Final Regulations, which were released on July 20, 2020, are based on proposed regulations issued by the IRS in 2019 (2019 Proposed Regulations) that included an exception from the GILTI rules for income subject to a relatively high rate of tax in a foreign country. In addition to the 2020 Final Regulations, the IRS issued a new set of proposed regulations (the 2020 Proposed Regulations) modifying the high-tax exception to the subpart F income (i.e.
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IRS Notice: ABA Tax Comments on Priority Guidance Plan for 2020-21
ABA Tax Section July 23 releases comments on 2020-21 Priority Guidance Plan in response to Notice 2020-47 . The comments focus on finalizing proposed regulations on consolidated net operating losses, minimum tax credit carryforwards, normalization requirements for excess tax reserves regarding tax code Section 168, and finalizing proposed regulations on the silo treatment of exempt organizations unrelated business taxable income, among others.
Your Taxes: GILTI regulations are a big win for small businesses - The Jerusalem Post
You Should Be Able to Challenge the IRS in Court | Cato @ Liberty
Although the Internal Revenue Service is responsible for collecting taxes, the power to write tax law is a legislative one, held by Congress. In certain cases, however, Congress has delegated to the IRS limited authority to fill in the gaps of tax laws through regulation. The Administrative Procedure Act (APA) lays out the processes that agencies like the IRS must follow when promulgating regulations, such as allowing for a period of public comment on proposed regulations.
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Indonesia: Tax facilities for gross split production sharing contract are finally implemented -
The Minister of Finance has issued Minister of Finance Regulation Number 67/PMK.03/2020 ('MoF 67/2020') on the Provisions of Value Added Tax Or Value Added Tax And Sales Tax on Luxury Goods, as well as Land And Building Tax Facilities In Upstream Oil And Gas Business Activities Under Gross Split Production Sharing Contract.
MoF67/2020 provides tax facilities during the exploration and exploitation phases until the commencement of Commercial Production, in the form of:
Opportunity Zones: A useful backup plan for 1031 exchanges - by Daniel Pessar : NYREJ
When real estate investors sell property, they often defer any capital gains using the like-kind, tax deferred exchange, provided for in Internal Revenue Code Section 1031. As explained in the tax regulations:
[A] deferred exchange is defined as an exchange in which, pursuant to an agreement, the taxpayer transfers property held for productive use in a trade or business or for investment (the “relinquished property”) and subsequently receives property to be held either for productive use in a trade or business or for investment (the “replacement property”). 1
European Commission to unveil changes to Mifid II amid covid crisis
Strict financial regulations in Europe, known as Mifid II, have been in place for over two years — but change is just around the corner.
The European Commission, the executive arm of the EU, will announce adjustments Friday to its Markets in Financial Instruments Directive (Mifid), which was first introduced in 2007 and then updated in 2018.
The regulation led to a separation of the trading and research arms of brokerage firms. The aim was to make their stock recommendations totally independent from their trading operations. However, the rules have led many brokers to stop publishing research on smaller firms as a way to reduce costs.
Bank Regulator Clarifies Crypto Custody Rules | Carlton Fields - JDSupra
On July 22, 2020, the Office of the Comptroller of the Currency (OCC) published an interpretive letter clarifying the authority of national banks and certain federal savings associations (FSAs) to provide their customers with cryptocurrency custody solutions.
The letter comes in response to a bank requesting clarity with respect to existing laws and regulations surrounding the provision of cryptocurrency custody services. The OCC letter recognizes that there is a significant demand for such services because of the unique and irreplaceable nature of cryptocurrency private keys, and the possibility that such keys can be used to sign an immutable transaction on a particular blockchain.
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