The bill contains several international tax provisions including:
- Making permanent the Subpart F exception under Secs. 953(e)(10) and 954(h)(9) for active financing income.
- A five-year extension, until December 31 2019, of Sec. 954(c)(6), which provides for lookthrough treatment of payments of dividends, interest, rents, and royalties received or accrued from related controlled foreign corporations under the foreign personal holding company rules. and
- Foreign taxpayers selling a interest in US real property will be subject to a higher 15% withholding tax as opposed to the previous tax of 10%.
Need Experienced International Tax Advice?
Contact the Tax Lawyers at
Marini & Associates, P.A.
for a FREE Tax Consultation
Toll Free at 888-8TaxAid (888)882-9243.
Journal of Accountancy