On July 20, 2020, Treasury issued final regulations allowing a high-tax election for global intangible low-taxed income (“GILTI”) purposes and proposed a further set of regulations that would unify that election and the Subpart F high-tax election. This Legal Update discusses some of the key issues and challenges associated with these new final and proposed regulations.
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In theory, the combination of the Section 250 deduction and the 80% foreign tax credit should effectively mean that a US shareholder should not pay residual US tax on a GILTI inclusion from CFC income that is subject to an effective rate of foreign tax of at least 13.125%. However, in practice, this often does not hold true as a result of the expense allocation rules and the inability to carryback or carryforward foreign tax credits in the GILTI basket.
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My Turn: Mike Stenhouse: Raise sails, not taxes - Opinion - providencejournal.com - Providence,
It is not the best of times, so it is the worst of times to raise taxes. But it seems that Rhode Island’s political leaders, after the brutal health and economic impact of this pandemic, care more about their precious state budget than they care about our family and business budgets.
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Are crypto-tax regulations ready for Ethereum's staking rewards? - AMBCrypto
Over the past decade, the crypto-market has diversified significantly and today, the average crypto-user has a wide variety of options in terms of coins and derivatives products to choose from. However, this growth hasn’t translated well when it comes to addressing issues pertaining to regulatory and tax compliance.
“People and many exchanges just didn’t do 1099 reporting because there’s actually a technical reason in the way the IRS has written the 1099 rules and that there was a legal basis for the exchanges not to do 1099 reporting.”
Should US companies have to play by a different set of rules? | TheHill
Inquiring about the business models and practices of leading companies is entirely appropriate. With success comes scrutiny. It is inappropriate, however, when foreign regulators deliberately put American firms on unequal footing. And yet that is what we are seeing, as regulators compete to be the first to hand down regulations against American technology services.
Just last month, Australian regulators proposed new draft laws nominally aimed at regulating commercial relationships between media companies and "digital platforms," but the Australian government has been explicit that the proposal applies only to Facebook and Google. Australian companies would not similarly be forced to pay for the privilege of sending Internet traffic to Australian media sites, nor be compelled to disclose changes to the "secret sauce" of their algorithms.
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Treasury Department, IRS Issue Final GILTI High-Tax Exception Regulations (Client Alert With
The final regulations addressing the GILTI high-tax exception retain the general approach of the proposed regulations with some simplifying changes.
This article is made available by Latham & Watkins for educational purposes only as well as to give you general information and a general understanding of the law, not to provide specific legal advice. Your receipt of this communication alone creates no attorney client relationship between you and Latham & Watkins. Any content of this article should not be used as a substitute for competent legal advice from a licensed professional attorney in your jurisdiction.
Green recovery or 'nightmare' for trade? Europe wants to tax emissions from ships - WENY News
Europe's plan to raise billions each year for coronavirus relief by charging ships for their pollution could inflame trade tensions at the worst moment for the global economy and set back efforts to tackle the climate crisis.
The European Commission is proposing to extend its Emissions Trading System (ETS) to shipping as one of a series of measures to help pay for rebuilding the EU economy, and to promote a green recovery from the crisis.
The European Union plans to spend 30% of its €750 billion ($889 billion) coronavirus recovery fund and next seven-year EU budget on climate-related projects in a bid to become the first carbon-neutral continent .
GILTI High-Tax Regs Show New Influence Of Book Income In Tax - Law360
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Opinion | Trump's unilateral actions were a brilliant political move.
House Speaker Nancy Pelosi (D-Calif.) lashed out at President Trump over the weekend for unilaterally extending the federal unemployment supplement and providing other relief to Americans struggling because of the pandemic. She called his executive actions " absurdly unconstitutional ." No, they are not. If anything, Trump's actions were restrained. He could have gone much further — and he still might.
In none of these cases did Trump rely on any presumed constitutional powers. But he could have gone much further by relying on the powers the Supreme Court recently granted him in Department of Homeland Security v. Regents of the University of California . In that case, the high court blocked his efforts to end President Barack Obama's Deferred Action on Childhood Arrivals, or DACA, program, which halted the deportation of people brought to the United States as children.
Happening on Twitter
Be careful what you wish for . But never stop wishing! IceBerg305 (from Miami, Fl) Mon Aug 17 03:56:39 +0000 2020
3 Rules I hope college athletes learn: 1-Be Careful What You Wish For.. 2-Never enter into negotiations with deman… https://t.co/8VRguw8cD5 dandakich (from Indianapolis, IN) Sun Aug 16 19:22:21 +0000 2020
Be careful what you wish for... lol https://t.co/x4mkxvOTG3 ImmortalTech (from The Heart of The Empire...) Wed Aug 12 04:05:16 +0000 2020
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