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Estate Taxation

  • FDII Qualification and Substantiation Requirements in the Final 250 Regulations

    Fernando Lopez, JD, MBA
    May 1, 2021

    Enacted by the Tax Cuts and Jobs Act of 2017, IRC Section 250 (Deduction for Foreign-Derived Intangible Income (FDII) and Global Intangible Low-Taxed Income (GILTI)) provides a favorable 50% U.S. tax deduction to shareholders of controlled foreign corporations (CFCs) on their GILTI deemed dividends.  In addition, Section 250 provides domestic C corporations a favorable 37.5% deduction on Foreign Derived Intangible Income that is derived from serving foreign markets via sales, services and licensing. This article primarily addresses issues related to the FDII deduction.

  • Purchasing Services from Foreign Persons

    Yelena Y. Antipova, Esq.
    Apr 1, 2021

    As technological advances have been evolving with a rapid rate, people have become more mobile. The pandemic of 2020 has only accelerated a further movement towards e-commerce. Companies can source services from anywhere in the world; people can provide services from anywhere in the world.

  • A New Environment for Estate Planning Takes Shape in 2021

    Kevin Matz, Esq., CPA, LLM (Taxation)
    Mar 1, 2021
    A new environment is starting to take shape in 2021, and with it comes additional considerations to factor into one’s estate planning. As a result of the success of Georgia Senate candidates Raphael Warnock and Jon Ossoff in their respective Senate races on January 5, the makeup of the new Senate is 50 representatives per party, with Democratic Vice President Kamala Harris holding a tiebreaking vote. 
  • Final Regs. on Deduction of Administration Expenses of Estates and Non-Grantor Trusts

    Kevin Matz, Esq., CPA, LL.M. (Taxation)
    Nov 1, 2020

    On September 16, 2020, the U.S. Department of Treasury (“Treasury”) and the IRS released final regulations on the deduction of administration expenses of estates and non-grantor trusts under sections 67(e) and (g), and on the treatment of excess deductions in the final year of the estate or non-grantor trust under section 642(h) (the “final regulations”).

  • Equity and Equity-Based Compensation for LLCs

    Robert M. Finkel
    Jun 1, 2020
    The structures for granting equity incentives to employees and other service providers of corporations are tried and true. The income tax consequences to a grantee upon his receipt of restricted stock and stock options and to the issuing corporations are well settled.
  • Form 5471 Reporting Refresher and Updates

    Justin Lynch
    Mar 1, 2020
    The Tax Cut and Jobs Act (TCJA), signed into law in December 2017, brought significant changes to U.S. international taxation. During the 2018 tax filing season, practitioners had to navigate the new reporting requirements of the deemed repatriation of offshore accumulated earnings and global intangible low-taxed income (GILTI), among other provisions.
  • Excess Benefit Transactions

    Magdalena M. Czerniawski, CPA, MBA, and Robert Lyons, CPA, MST
    Jan 1, 2020
    Excess benefit transactions (EBT) are an outgrowth of IRC section 4958, which was first introduced in 1996 and modified in 2003. Its purpose was to punish the wrongdoer but not necessarily revoke the exemption of what may be a perfectly good charitable organization with bad management.

Views expressed in articles published in Tax Stringer are the authors' only and are not to be attributed to the publication, its editors, the NYSSCPA or FAE, or their directors, officers, or employees, unless expressly so stated. Articles contain information believed by the authors to be accurate, but the publisher, editors and authors are not engaged in redering legal, accounting or other professional services. If specific professional advice or assistance is required, the services of a competent professional should be sought.