April 2019 Newsletter

An overview of the proposed regs on the FDII and GILTI deduction

In March, the IRS issued proposed regulations that cover how to determine the amount of the deduction for foreign-derived intangible income (FDII) and global intangible low-taxed income (GILTI). The regs also coordinate the FDII and GILTI deduction with other tax provisions. This article provides an overview of the proposed regs.

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Proposed regs set out how to determine FDII

In March, the IRS issued proposed regulations that cover determining the amount of the deduction for foreign-derived intangible income (FDII) and global intangible low-taxed income (GILTI). The regs also coordinate the FDII and GILTI deduction with other tax provisions. This article covers many of the specific details involved with determining FDII.

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Court defines “financial interest” and makes other FBAR rulings

A district court ruled in January on various issues regarding the Report of Foreign Bank and Financial Accounts (FBAR). This article reviews the case and discusses its impact on the statute of limitations for assessing penalties and the definitions of various FBAR terms, including the term “financial interest.”

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