The Internal Revenue Code imposes a variety of limitations and obstacles to individual taxpayers’ ability to deduct certain types of losses. There are generally three different types of losses covered...
A mezzanine loan is a type of subordinate loan that is indirectly secured by real property. Unlike a mortgage loan, which is directly secured by real property, a mezzanine loan is secured by a pledge of...
Rely on this new visual checklist from Practical Guidance – Healthcare to determine whether a data breach constitutes a reportable breach of protected health information (PHI) under the Health Insurance...
Mergers and asset sales can be viable alternatives for companies in financial distress seeking to avoid bankruptcy. Financially distressed companies also present unique opportunities for investors and...
Check out checklists for necessary steps for cancelling trademark proceedings or issuing a notice of opposition at the Trademark Trial and Appeal Board (TTAB). The checklists include coverage of general...
Review the fundamentals of the global intangible low-tax income (GILTI) and the foreign-derived intangible income (FDII) tax regimes. GILTI and FDII were both created by the Tax Cuts and Jobs Act of 2017 (TCJA). Pub. L. No. 115-97. The TCJA enacted I.R.C. Section 951A, which requires U.S. shareholders who own (within the meaning of I.R.C. Section 958(a)) a CFC to include GILTI in gross income. Form 8992 is used by a U.S. shareholder to calculate the amount of the GILTI inclusion and to report related information.
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