Our Thoughts On

Build Back Better Tax Legislation Update – International Tax Changes

This article summarizes the proposed changes regarding international tax provisions of the Tax Cuts and Jobs Act (TCJA). The Build Back Better proposal will mainly affect the Global Intangible Low-Taxed Income (GILTI) regime, Subpart F regime and foreign tax credit, Section 250 deduction, and Foreign-Derived Innovation Income (FDII), BEAT, and SHIELD.

Proposed Tax Changes to GILTI

Learn more about the Global Inclusion of Low-Tax Income (“GILTI”) and how the proposed changes may impact you.

Tax Reform 2021 - Build Back Better: Proposed Changes to Section 199A Qualified Business Income Deduction

Learn more about the proposed changes to section 199A qualified business income deduction under the Build Back Better Act.

Tax Reform 2021 - Build Back Better: Excess Business Losses Further Limited than Under 2017 Tax Cut and Jobs Act

Learn more about the excess business losses being further limited under the Build Back Better proposal and changes in the current law.

Tax Reform 2021 – Build Back Better: Proposed Changes to Increase Net Investment (NII) Income Tax on S Corporation Shareholders and Limited Partners

Learn more about the proposed expansion of scope to the existing income subject to the Net Investment Income (NII) tax, originated under the Affordable Care Act.

Tax Reform 2021 – Build Back Better: Temporary Rule for S-Corporation Conversions to Partnerships

Learn more about the proposed Build Back Better Act legislation Temporary Rule for S-Corporation Conversions to Partnerships.