global intangible low-tax income Archives

global intangible low-tax income

Omitted Subpart F and GILTI Income May Be a Statute of Limitations Trap for the Unwary

by Kevin Spencer and McDermott Will & Emery | Dec 17, 2021 | IRS Guidance, Tax Reform

Taxpayers large and small desire closure with respect to tax reporting positions. This can occur in several ways, one of which is the closing of the limitations period for assessing additional tax. In this article published in the November-December 2021 issue of the International Tax Journal, McDermott Partners Andrew R. Roberson and Kevin Spencer discuss recent Internal Revenue Service (IRS) guidance relating to the limitations period for omitted Subpart F income.

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Tax Reform Conference Committee Reaches Agreement

by Timothy S. Shuman, McDermott Will & Emery, David G. Noren, Lowell D. Yoder and Sandra P. McGill | Dec 18, 2017 | IRS Guidance, Tax Reform, Uncategorized

A House-Senate conference committee has reached agreement on a compromise version of the Tax Cuts and Jobs Act, which includes substantial changes to the corporate and international business taxation rules. The stage now appears to be set for final passage and enactment of the legislation before the end of 2017.