June 2014 Election Deadlines for Retroactive Application of New Foreign Affiliate Reorganization Rules

Author: Geoffrey S. Turner

This article examines the new foreign affiliate reorganization provisions and key elections affecting Canadian corporations with foreign affiliates. It may now be possible for taxpayers to clarify, proactively confirm, or even change the intended tax consequences of historic transactions that closed after December 20, 2002.

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Key Contacts

Geoffrey S. Turner
Geoffrey S. Turner

Senior Counsel




IRS Finalizes High-Tax Exception to GILTI

July 22, 2020 - The U.S. Treasury Department and the IRS have released final regulations (2020 Final Regulations) allowing certain domestic shareholders of a “controlled foreign corporation” (CFC) to elect under a high-tax exception to opt out of the tax imposed on the CFC’s “global intangible low-taxed...