The final and proposed regulations under sections 951A and 954 of the US Internal Revenue Code contain certain rules that may present planning opportunities—or possibly onerous results—depending on a taxpayer’s specific fact pattern.
During this program, we will illustrate some of the benefits and drawbacks that may arise from these regulations, and provide you with practical considerations that will help you navigate the decision as to whether to make an election to apply the global intangible low-taxed income (GILTI) high-tax exclusion. We will discuss:
This may worth something:
High time: Final and proposed regulations rework high-tax rule for GILTI and subpart F - Lexology
Recently released final regulations provide some relief to taxpayers that are subject to high foreign taxes on their global intangible low-taxed income (GILTI), but whether the GILTI high-tax exclusion is beneficial to any given taxpayer will require annual calculations as there are trade-offs to making the election.
* * *
The 2020 Proposed Regulations detail changes to the subpart F high-tax exception to conform the exception to the GILTI high-tax exclusion, which would:
This week in tax: Pillar one and pillar two documents are leaked | International Tax Review
The pillar one blueprint attempts to simplify the proposals and includes numerous flowcharts to demonstrate the application of Amount A in the three-tier profit allocation rules. The pillar two blueprint includes detailed definitions of in-scope and excluded entities.
The scope in the pillar one blueprint states that revenue thresholds, segmentation and profit allocation will be used to determine which entities will be liable for tax, but it does not specify the thresholds. In addition, Annex A of the blueprint provide a process map, illustrating how the new taxing right under Amount A will apply in practice.
Rick Laib, 11th Congressional District Republican nominee - Chicago Sun-Times
Education: ThM: Trinity International University, MA: Biola University, BA: University of St. Francis
* * *
The Chicago Sun-Times Editorial Board sent nominees for the U.S. House of Representatives a list of questions to find out their views on a range of important issues facing their districts, the state of Illinois and the country. Rick Laib submitted the following responses:
Are you satisfied with the federal government's response to the COVID-19 pandemic? Why or why not? What grade would you give President Donald Trump for his handling of the pandemic, and why?
And here's another article:
Plan Now for Reduction in Estate, Gift and GST Tax Exemptions
As part of the Tax Cuts and Jobs Act of 2017, the gift and estate tax exemption amount was doubled in 2018 from $5 million to $10 million, adjusted for inflation. With the inflation-adjusted amount in 2020 being $11.58 million, today, a married couple can transfer, without considering the availability of any deductions or exclusions, approximately $23 million before having to pay a federal gift or estate tax.
Of course, Congress could take action to change the gift and estate tax exemption prior to 2026. Although it seems highly improbable that any such action will be taken in 2020, many commentators believe that after the election, a new Congress may enact changes as early as next year. Therefore, it may be advisable to act before the end of this year if you wish to take advantage of the law as it exists today.
SECURE Act Tax Credit
Notice 2020-68 from the IRS provides valuable clarification for sponsors of qualified plans, 403(b) plans, and 457(b) governmental plans, as well as IRA holders, related to certain provisions in the Setting Every Community Up for Retirement Enhancement Act of 2019 (SECURE Act) and the Bipartisan American Miners Act of 2019.
A new tax credit under the SECURE Act aims to offset the costs of establishing and maintaining a qualified employer plan that provides an eligible automatic enrollment arrangement (EACA). The $500 credit is also available to eligible employers that amend an existing plan to add an EACA.
IRS PLR: American Business Networking Organization Exempt Status Denied for Failing Operational
Mark C. Curran Jr., U.S. Senate Republican nominee profile - Chicago Sun-Times
Political/civic background: Lake County Sheriff 2006-2018/Numerous Law Enforcement and Community Boards
* * *
Education: High School -- Loyola Academy, Wilmette, IL; College -- Spring Hill, Mobile, Alabama BS in Business Administration; Law School -- IIT Chicago-Kent College of Law, Chicago, Illinois; Suburban Law Enforcement Academy -- Certified Law Enforcement Degree, Wheaton Illinois. Additionally, I hold numerous advanced law enforcement degrees.
Happening on Twitter
TEACHERS: Next week (9/9), a webinar will discuss how the virtual #NatBookFest can work with your instructional pla… https://t.co/PEzy2JsVyz librarycongress (from Washington, DC) Fri Sep 04 18:51:37 +0000 2020
Seminario Latinoamericano Virtual #NiñezPrimero CINE PARA NIÑAS, NIÑOS Y ADOLESCENTES EN EL CONTEXTO DE LA PANDEMI… https://t.co/sr6emkFeEI derechoinfancia (from México) Sat Sep 05 00:17:02 +0000 2020
10 year ago Share Our Strength created the No Kid Hungry campaign to help hungry children across the country. Want… https://t.co/0a1Mzotfrb nokidhungry (from Washington, DC) Sat Sep 05 19:05:02 +0000 2020
Hari ini ada acara webinar dan launching M3I Majelis Mudzakarah Masjid Istiqlal. Gus Nadirsyah Hosen akan turut men… https://t.co/PtCpvwpFgX na_dirs (from Clayton, Victoria) Wed Sep 02 00:55:49 +0000 2020
No comments:
Post a Comment