On July 20, 2020, the US Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued proposed regulations (REG-127732-19) (the 2020 Proposed Regulations) that would conform the historic Subpart F high-tax exception under section 954(b)(4) with the new global intangible low-taxed income (GILTI) high-tax exception.
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Subpart F High-Tax Exception under Section 954(b)(4) and Treas. Reg. § 1.954-1(d)
Section 951(a)(1) generally requires a US shareholder of a CFC to include in gross income its pro rata share of the corporation’s Subpart F income for a taxable year. However, a US shareholder may elect to exclude from its gross income any item of Subpart F income that is subject to a high foreign income tax rate.
Other things to check out:
Vermont May Be the Next State to Legalize Recreational Marijuana Sales
According to news reports , the Vermont legislature is ready to advance S54 this month or next, to legalize cultivation and sales of marijuana in the state beginning in 2022. Versions of the bill have been approved by both chambers. The current regulatory situation in Vermont is unique, as marijuana possession has been legal since January 2018. Before heading to the governor for signature, the two chambers will have to work out their differences in bicameral committee.
Treasury Department, IRS Issue Final GILTI High-Tax Exception Regulations | Latham & Watkins LLP
The final regulations addressing the GILTI high-tax exception retain the general approach of the proposed regulations with some simplifying changes.
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..Taxpayers can elect on an annual basis whether to exclude income subject to high foreign taxes from the computation of GILTI minimum tax on foreign earnings.
..Taxpayers can make this election retroactively for tax years beginning on or after January 1, 2018.
Key Takeaways from the Proposed Regulations on Carried Interest - Lexology
As background, Section 1061 applies to an applicable partnership interest (an “API”) held by or transferred to a taxpayer in connection with the performance by that taxpayer (or a related person) of substantial services in an applicable trade or business (an “ATB”).
The Proposed Regulations apply to tax years beginning on or after the date that final regulations are published (with some exceptions noted below), though taxpayers are generally allowed to rely on them prior to that date, if applied consistently. The IRS and the Treasury have requested comments on the Proposed Regulations. The Proposed Regulations could change significantly prior to finalization.
In case you are keeping track:
DNP Select Income Fund Inc. Section 19(a) Notice
The following table sets forth the estimated amounts of the current distribution, payable August 10, 2020 , together with the cumulative distributions paid this fiscal year-to-date (YTD) from the following sources. The fiscal year is November 1, 2019 to October 31 , 2020. All amounts are expressed per share of common stock based on U.S. generally accepted accounting principles, which may differ from federal income tax regulations.
Proposed rules govern carried interests - Journal of Accountancy
The IRS issued proposed regulations ( REGS-107213-18 ) on the tax treatment of carried interests. Carried interests are ownership interests in a partnership that share in the partnership's net profits. They are often transferred in connection with the performance of substantial services by an individual. Proceeds from that individual's partnership interest are often taxed as capital gain rather than ordinary income. The law known as the Tax Cuts and Jobs Act, P.L.
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The proposed regulations also include related clarifying amendments to Regs. Sec. 1.702-1(a)(2) and Regs. Sec. 1.704-3(e).
President Trump extends unemployment benefits, defers payroll tax
BEDMINSTER, N.J. - Bypassing Congress, President Donald Trump has signed executive orders deferring payroll taxes for some Americans and extending unemployment benefits, but at a lower weekly amount, after negotiations on a new coronavirus rescue package collapsed.
Trump accused Democrats of loading up their rescue bill with things unrelated to the coronavirus. "We've had it," he said at a news conference at his country club in Bedminister, New Jersey, as he signed four executive orders.
The Wallets of Wall Street Are With Joe Biden, if Not the Hearts - The New York Times
As Wall Street donors arrived at a fund-raiser for Joseph R. Biden Jr. at a Midtown Manhattan restaurant earlier this year, campaign staff members asked if they wanted to sign up for pictures with the candidate. More than a few of the bankers and private-equity investors politely declined, opting to mingle over glasses of wine instead.
And finance executives have played a critical role in helping him do it. As Mr. Biden survived a turbulent winter to become the presumptive Democratic nominee running against President Trump , the millions of dollars Wall Street denizens donated to Mr. Biden and outside groups supporting his candidacy have helped him build a strong lead in national polls.
Happening on Twitter
(1/2) The best parts of these executive actions have already been proposed by Congress, but the Senate leader never… https://t.co/76cMBRtkJ2 AmyMcGrathKY (from Georgetown, KY) Sat Aug 08 22:44:14 +0000 2020
AGE IS JUSTT A NUMBER: 76-year-old Jeffrey Miller just proposed to his girlfriend, 71-year-old Gloria Alexis, at th… https://t.co/0THWEJLXxZ CBSNews (from New York, NY) Fri Aug 07 18:14:54 +0000 2020
Let's put a finer point on this for everybody. Trump just proposed that we stop funding Social Security and Medicar… https://t.co/Qhghig8F60 aravosis (from Washington, DC) Sat Aug 08 21:14:17 +0000 2020
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