U.S. Tax Review: International Tax Reforms, Subpart F and GILTI Changes, Eaton and Bittner, FBAR Penalties

By: Larissa B. Neumann , Julia Ushakova-Stein , Michael Knobler

In this installment of U.S. Tax Review, tax partners Larissa Neumann, Julia Ushakova-Stein and Mike Knobler review the Biden administration’s international tax reform proposals, final regulations that modify subpart F and GILTI rules for consolidated groups, recent developments regarding the Eaton and Bittner cases, and IRS guidance on section 961 and sourcing.

Read the full commentary and analysis in Tax Notes.