Topic
FDII
4 published works
Inside SALT
CARES Act Could Result in Taxation of More GILTI in New Jersey
By Alysse McLoughlin, Kathleen M. Quinn
The federal stimulus bill (the CARES Act), HR 748, which was signed into law by President Trump on March 27, includes certain corporate income tax provisions designed to provide relief…
The CPA Desk
How to Maximize Opportunity with FDII
By PKF Texas
https://youtu.be/6OYHPJR4xTs Jen: This is the PKF Texas Entrepreneur’s Playbook. I’m Jen Lemanski and I’m back again with Frank Landreneau, one of our International Tax Directors. Frank, welcome back to The…
SALT Shaker
It’s Not the Eggnog – New Jersey Proposes to Specially Allocate GILTI Based on GDP
On December 21, the New Jersey Division of Taxation released Technical Bulletin TB-85, which addresses how the Division will expect taxpayers to calculate the amount of so-called global intangible low-taxed…
Tax Controversy 360
Tax Reform Insight: Eligibility Requirements for Reduced Tax Rate on FDII for Royalties
By David G. Noren, Lowell D. Yoder, Elizabeth Chao
A domestic corporation's royalty income derived in connection with business conducted outside the United States generally is eligible for the reduced 13.125 percent effective tax rate on foreign derived intangible…