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Full-Text Articles in Law
Federal Income Taxation, Nikolai Karetnyi, Ruoxi Zhang
Federal Income Taxation, Nikolai Karetnyi, Ruoxi Zhang
Mercer Law Review
In the year 2019, the federal courts within the Eleventh Circuit handed down several notable opinions on federal tax issues. This Article surveys two of those opinions involving the taxation of shareholder loans to S corporations and the application of gross valuation-misstatement penalty to partnerships.
More Anti-Simplification: How Pti And Gilti Override The Section 245a Exemption And The U.S. Territorial Tax System, Christine A. Davis
More Anti-Simplification: How Pti And Gilti Override The Section 245a Exemption And The U.S. Territorial Tax System, Christine A. Davis
Mercer Law Review
In December of 2017, the United States (U.S.) enacted tax reform commonly known as the “Tax Cuts and Jobs Act” (TCJA), which was initially thought to “establish[] a territorial tax system for multinational companies.” Over time, however, tax professionals began to understand that the TCJA layered a territorial tax system that exempted foreign earnings from the U.S. income tax (exemption tax system) on top of a residence-based worldwide tax system that used a foreign tax credit (FTC) to protect against juridical double taxation (worldwide tax system). Furthermore, the U.S. exemption tax system is severely limited by the worldwide tax system. …