tax reform - international tax changes
Transition Tax (Section 965) -
Global Intangible Low Taxed Income (GILTI) -
Foreign Derived Intangible Income (FDII) -
Withholding on Transfer of Partnership Interest by Foreign Persons - new tax law treats a foreign partners gain or loss on the sale of a partnership interest as effectively connected income to the extent that gain or loss would be treated as effectively connected income if the partnership sold all its assets. Additionally, a transferee is now also required to withholding tax of 10% of the gross amount realized on the sale of the interest by a foreign partner.
Please contact us to learn how these changes affect you and your business.