International corporate tax reform and partnership taxation : fitting a triangular peg into a rectangular hole

Resource Information

The work International corporate tax reform and partnership taxation : fitting a triangular peg into a rectangular hole represents a distinct intellectual or artistic creation found in International Bureau of Fiscal Documentation. This resource is a combination of several types including: Work, Language Material, Continuing Resources.

Label

International corporate tax reform and partnership taxation : fitting a triangular peg into a rectangular hole

Creator

• Schockett, P.E
• Stevenson, R.C

Subject

• GILTI
• TCJA
• corporate income tax
• disposal
• BEAT
• foreign tax credit
• partnership
• tax reform
• effectively connected income
• CFC

Language

• eng
• eng

Summary

This article highlights and discusses interactions between the Tax Cuts and Jobs Act (TCJA) reforms to U.S. federal income taxation of international businesses and the operation of subchapter K. The article contains six main sections. The first discusses certain interactions of the indirect foreign tax credit provisions under revised Code Sec. 960 and partnerships. Next, there is a discussion of the new global intangible low-taxed income (GILTI) regime under Code Secs. 951A and 250 and some questions that arise when a controlled foreign corporation, within the meaning of Code Sec. 957(a) (a CFC), is owned through a domestic partnership or when a CFC itself owns a partnership interest. After the GILTI discussion, the new base erosion anti-abuse tax (BEAT) under Code Sec. 59A is considered in the context of payments to or by a partnership. Following that we address the interaction of the expanded interest deductibility limitation under Code Sec. 163(j) in the context of a CFC owned by a partnership. The fifth main section is a discussion of the new rule in Code Sec. 864(c)(8) pursuant to which a foreign person's gain or loss on the disposition of an interest in a partnership which is engaged in any trade or business within the United States is treated as gain or loss effectively connected with the conduct of such trade or business, and the article's final main section contains a discussion of two other miscellaneous issues that have arisen as a result of the TCJA

Citation source

In: International tax journal. - Riverwoods. - Vol. 44 (2018), no. 4 (July-August) ; p. 1-16

Geographic coverage

North America

Language note

English