Thursday, November 5, 2020

Government Revises Base Difference Rules in New Foreign Tax Credit Regulations | McDermott Will &

On September 29, 2020, the US Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued final regulations (TD 9922) (the 2020 Final Regulations) and related proposed regulations (REG-101657-20) (the 2020 Proposed Regulations) that address the treatment of “base differences” for purposes of allocating and apportioning foreign taxes.

The 2019 Proposed Regulations provided a detailed framework for allocating and apportioning foreign taxes that was generally consistent with existing law: Taxes are allocated and apportioned on the basis of the income as computed under foreign law on which the tax is imposed. In general, under the 2019 Proposed Regulations, foreign gross income is assigned to the grouping to which the corresponding US item is assigned.

Publisher: JD Supra
Twitter: @jdsupra
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This may worth something:

Final BEAT Regulations Contain Promise and Pitfalls for Taxpayers - Lexology

The BEAT serves as a minimum tax on payments to foreign related parties: 5% for 2018, 10% for 2019-2025, and 12.5% thereafter.2 The tax applies to “applicable taxpayers,” defined as corporations (other than regulated investment companies, real estate investment trusts, or S corporations) with at least $500 million average annual gross receipts over the previous three taxable years and whose “base erosion percentage” is 3% or higher.3 The “base erosion

To address this concern, the Department of the Treasury included in its proposed BEAT regulations issued December 2, 20196 an election allowing taxpayers to waive deductions for the purposes of BEAT, and has maintained this election in the final regulations.7 By making this election, taxpayers who may be applicable taxpayers under BEAT may waive deductions that they would otherwise be able to claim in order to reduce their base erosion percentage, and thus avoid application of, and liability

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Investors welcome U.S. election gridlock, retreat from 'blue wave' bets | Reuters

NEW YORK (Reuters) - Investors who met news of likely gridlock in Washington with a large-scale unwind of bets on a Democratic sweep weighed prospects for big stimulus measures while cheering fading expectations of higher taxes and new regulations.

Regardless of whether Democrat Joe Biden or Republican Donald Trump wins the presidency, some investors on Wednesday welcomed the prospect that either candidate would likely face some opposition in Congress that would be a barrier to sweeping legislative changes.

Publisher: U.S.
Date: 2020-11-04T03:32:41Z
Author: David Randall Lewis Krauskopf
Twitter: @Reuters
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Here's why the stock market is rallying even though the election outcome is still uncertain

The lack of a blue wave makes higher taxes and more regulation less likely, and that's enough to rally stocks for now.

Stocks bounced higher Wednesday, led by the Nasdaq which rose 3.9% as big tech, like Amazon and Apple surged. Bond yields fell, as investors bought bonds as a hedge against uncertainty and also as a big stimulus package looks far less likely.

The typically subdued Treasury market was also volatile. The yield on the benchmark 10-year ran up to 0.94% Tuesday night on early expectations of a blue wave, or Democratic sweep, but reversed sharply and fell to 0.75% Wednesday. Rates had been rising on the expectations that a big stimulus package from Democrats could result in much more government debt and inflation.

Publisher: CNBC
Date: 2020-11-04T19:07:26 0000
Author: https www facebook com CNBC
Twitter: @CNBC
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Many things are taking place:

Mid Hudson small business owners say how next president, Congress can help

Mid Hudson small business owners took time Tuesday, before Election Day results were tabulated, to suggest how the next president and Congress can best help them.

Small employers, those with fewer than 100 workers, account for 98.2 percent of U.S. businesses and 97.4 percent in New York, according to state Comptroller Thomas DiNapoli.

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That's especially true, Flynn added, because it's unclear when businesses like restaurants will be permitted to operate at full capacity or, for that matter, when every customer will feel comfortable coming back.

Publisher: Times Herald-Record
Date: Times Herald-Record
Author: Daniel Axelrod
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A by-the-numbers look at state regulations puts Ohio near the top

A team of data analysts from the center found that the average state has about 135,000 regulatory restrictions in its administrative rules.

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California, for instance, is the most-regulated state, with 395,608 regulatory restrictions, while Idaho is the least-regulated state, with just 38,961 regulatory restrictions.

Obviously, these numbers are a blunt tool. As research fellow Kofi Ampaabeng points out, "Regulations can have a variety of impacts on an economy, business and individual. RegData has served as the starting point to understand the size and scope of both state and federal regulations."

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Publisher: Crain's Cleveland Business
Date: 2020-11-04T13:52:39-0500
Author: Scott Suttell
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Montana marijuana: Here's what to know about legal weed, restrictions

Montana voters passed two ballot initiatives Tuesday , paving the way for the state to legalize recreational marijuana use. Both ballot measures were required to pass in order for recreational marijuana use to be permitted in the state.

Just because the measures passed, though, doesn't mean you can go out and buy it just yet. The state will still need to set up rules, regulations and begin the process for applications for dispensaries.

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The passage of complementary ballot initiatives I-90 and CI-118 has legalized the recreational use of marijuana for adults in the state over the age of 21.

Publisher: Great Falls Tribune
Author: Megan Bridgeman and Grady Higgins
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Trump runs in rural America on ethanol, tax cuts, regulatory relief | Successful Farming

President Trump is ending his re-election campaign in rural America on the same issues that boosted him in 2016: Promises of tax cuts, fewer federal regulations, and support for corn ethanol. In addition, farmers are wealthy from $23 billion in trade-war payments, said Trump in Dubuque, Iowa, on Sunday; "That's why you're all here and you're all happy."

"As president, I kept my promise. And I protected ethanol, and I approved E15 for year-round use. You don't know what that means. That's a lot," said Trump in Dubuque. "Authorized its use on existing pumps. Also that doesn't mean a lot to you. It means a lot to the ethanol people."

Publisher: Successful Farming
Date: 2020-11-02T09:04:21-06:00
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