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Here’s a quick glance at how PSEi stocks fared on Friday , November 22, 2024 .Taxpayers have been eagerly awaiting, and the US Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) have been promising to provide, rules addressing the previously taxed earnings and profits (PTEP) of foreign corporations. On November 30, 2024, the Treasury and the IRS made good on their promise. The proposed PTEP regulations are generally welcome news for taxpayers seeking certainty about long-standing issues, including the treatment of mid-year distributions, Section 961(c) basis, and partnerships that hold foreign corporations. However, those welcome developments come at the cost of substantial complexity and several taxpayer-unfavorable provisions. In this On the Subject , we provide a brief overview of PTEP and why it matters and share five key takeaways from the proposed regulations. In Depth OVERVIEW OF PTEP The PTEP rules provide that when earnings of a foreign corporation have been included in the US shareholder’s gross income, when those earnings are distributed, they are excluded under Section 959(a) from the US shareholder’s gross income to ensure the same earnings are not subject to US taxation twice. Under Section 959(b), PTEP distributions from a lower-tier controlled foreign corporation (CFC) to an upper-tier CFC are also excluded from the upper-tier CFC’s income for purposes of determining the upper-tier CFC’s gross income. The Section 961 rules provide for adjustments in the US shareholder’s basis in CFC stock to prevent taxpayers from obtaining a loss when the stock is sold before PTEP is distributed. Under Section 961(a), Subpart F and global intangible low-taxed income (GILTI) inclusions increase the US shareholder’s basis in the CFC. Under Section 961(b), distributions decrease it. Section 961(c) provides that similar adjustments are made to an upper-tier CFC’s basis in a lower-tier CFC but only for purposes of determining the amount included under Section 951 in the gross income of a US shareholder. The PTEP rules have become much more important to US-based multinationals since the Tax Cuts and Jobs Act of 2017 (TCJA) vastly increased the amount of foreign corporations’ earnings subject to current US taxation as GILTI. Post-TCJA, some shareholders may even prefer a distribution of untaxed earnings and profits, which may qualify for the Section 245A dividends received deduction and does not require a Section 961(b) reduction in basis. The current Section 959 PTEP regulations are from 1965 and do not address many key issues. In 2006, the Treasury and the IRS issued proposed PTEP regulations, but the proposed regulations did not expressly permit taxpayer reliance, and the rules were withdrawn in 2020. The newly proposed rules are complex, but here are five key takeaways to keep in mind: 1. They Are Generally Prospectively Effective and Cannot Be Relied Upon Now (But Can Be Relied on Retroactively if and When the Rules Are Finalized). Most of the regulations will be effective for taxable years ending on or after the date the regulations are finalized. Taxpayers are not allowed to rely on the proposed regulations prior to them being finalized. The Treasury has indicated that they did not allow taxpayers to rely on the regulations while in proposed form because of the complexity of the rules and the fact that they introduce new concepts not previewed in prior guidance. The regulations may also be changed before finalization after considering taxpayer comments. However, once the rules are finalized, taxpayers will be able to elect to apply them retroactively to any open tax years as long as they apply all of the proposed rules in full and are consistent about applying the rules to related corporations. The rules include transition rules to bridge years for which the regulations are effective with prior years. 2. They Require Shareholder and Foreign-Corporation-Level Accounting. The proposed PTEP rules are quite complex in that they require PTEP to be tracked at both the US shareholder and the foreign corporation level. In addition to PTEP, shareholders must track (1) a US dollar basis pool, which is their US dollar basis in the original PTEP inclusion for purposes of recognizing foreign exchange gain or loss under Section 986(c), and (2) a PTEP tax pool, which is the US dollar basis of foreign income tax pools associated with the US dollar basis pool. The proposed rules largely follow the ordering rules set forth in Notice 2019-01, which was released in late 2018. These rules generally require that 10 different PTEP groups be tracked within each Section 904(d) foreign tax credit category on an annual basis. To slightly simplify compliance, taxpayers may elect to combine years within a PTEP group and Section 904(d) foreign tax credit category, rather than tracking each year separately. These ordering rules include a rule to treat Section 965(a) and Section 965(b) PTEP, which resulted from the one-time transition tax as part of the TCJA, as being distributed first before other types of PTEP (even PTEP earned in a more recent tax year). The rule was aimed at reducing complexity by allowing Section 965 PTEP to come out first so corporations and the IRS would not have to track Section 965 PTEP groups in perpetuity. The proposed PTEP regulations set forth rules for when adjustments to PTEP and associated stock basis are made. One key rule is that increases to PTEP for GILTI or Subpart F inclusions are done at the beginning of the year, so PTEP (and the associated stock basis) is available for mid-year distributions. 3. They Adopt a Share-by-Share Approach to Section 961 Basis The proposed regulations provide that, unlike PTEP accounts, section 961 basis is specific to particular shares or items of property, such as partnership interests. The timing of basis adjustments is intended to generally match the timing of adjustments to PTEP accounts. The share-by-share approach to section 961 basis differs from the proposed regulations’ approach to section 959, which does not tie particular dollar basis pools of PTEP to particular shares held by a US shareholder. In certain cases, this mismatch could give rise to a shareholder recognizing gain on some shares even though the shareholder has unrecovered basis on other shares, a result arguably inconsistent with the repatriation-facilitating goal of the TCJA. Taxpayers should consider whether they have “lumpy” basis in CFC stock that could give rise to such a mismatch. Post-TCJA, a distribution of PTEP (historically a good attribute) may be less favorable in certain circumstances than a distribution of untaxed earnings and profits that qualifies for the Section 245A dividends received deduction and generally does not require a reduction in basis. 4. They Provide Detailed Rules for Lower-Tier Basis In addition to providing rules for Section 961(a) basis, the proposed regulations also provide rules for lower-tier basis, including both (1) “derived basis” (a new term applicable to shares or partnership interests owned by a partnership and distinct from the partnership’s common basis in such shares or partnership interests), and (2) Section 961(c) basis (applicable to shares of a lower-tier CFC owned by an upper-tier CFC). The proposed regulations provide that both derived basis and Section 961(c) basis can be negative. Derived basis can be negative to the extent of common basis; amounts exceeding the common basis are recognized as gain. Taxpayers should be careful to track Section 961(c) basis – yet another separate type of basis or account to track – to ensure that “negative” Section 961(c) basis is not inadvertently triggered as gain, which can even occur in connection with transactions that are otherwise nonrecognition transactions. 5. They Don’t Address Certain Key Items As expected, the proposed regulations do not address certain key items, such as whether/how PTEP transfers from one shareholder to another in Section 304 transactions, redemptions, and most nonrecognition transactions, such as 351 transactions and liquidations. The Treasury and the IRS plan to address those issues in a second tranche of PTEP guidance. The proposed regulations also do not address what happens to Section 961(c) basis when an upper-tier CFC inbounds to the United States ( e.g. , whether the Section 961(c) basis can be used as “regular” basis), which Notice 2024-16 permits in the case of “covered inbound transactions.” CONCLUSION The proposed PTEP regulations cover a lot of ground. The Treasury and the IRS have requested comments on several provisions and encourage taxpayers to provide comments on whether the proposed regulations get it right. Taxpayers should study the rules carefully and consider whether there are provisions worth asking the Treasury and the IRS to reconsider.None
INVESTIGATION ALERT: Edelson Lechtzin LLP Announces Investigation Zeta Global Holdings Corp. (NYSE: ZETA) and Encourages Investors with Substantial Losses or Witnesses with Relevant Information to Contact the FirmNominations Open for 2025 Defense IT Summit Flywheel AwardsKane hat trick against Augsburg hides Bayern's concerning lack of goals
BOSTON (AP) — Jaylen Brown scored the Celtics’ first 15 points on five consecutive 3-pointers and finished with 29 points, before Boston withstood a late charge to beat the Minnesota Timberwolves 107-105 on Sunday. Jayson Tatum added 26 points and eight rebounds to help Boston post a season-high fifth straight victory. Anthony Edwards had 28 points and nine rebounds for Minnesota, which has lost five of its last seven. Julius Randle added 23 points, and Rudy Gobert finished with 10 points and 20 rebounds, his eighth double-double of the season. Minnesota got within 55-54 early in the third quarter, before a 14-0 run by Boston. The spurt featured four 3s by the Celtics, including two by Tatum. The lead grew to 79-60 with 4:26 to play in the period. But the Timberwolves chipped it all the way down in the fourth, getting within 107-105 with 34 seconds left on a driving layup by Randle. Timberwolves: Minnesota will be looking to for some wins at home, after dropping four of its last five on the road. Celtics: The Celtics have struggled at home at times this season but improved to 6-2 at the Garden. The Timberwolves had the ball with 7.1 seconds and a chance to win. Edwards got the inbounds and tried to drive on Brown. But he was cut off, and the ball swung to Naz Reid, who failed to get off a 3 as time expired. Boston assisted on 25 of its 37 made field goals. The Timberwolves host Houston in NBA Cup play on Tuesday, beginning a four-game homestand. The Celtics host the Los Angeles Clippers on Monday night. AP NBA: https://apnews.com/hub/nbaFrom Botox jabs to laser treatments – Kim Kardashian admits there’s nothing she won’t do to look youngerNEW YORK — Chuck Woolery, the affable, smooth-talking game show host of "Wheel of Fortune," "Love Connection" and "Scrabble" who later became a right-wing podcaster, skewering liberals and accusing the government of lying about COVID-19, has died. He was 83. Mark Young, Woolery's podcast co-host and friend, said in an email early Sunday that Woolery died at his home in Texas with his wife, Kristen, present. "Chuck was a dear friend and brother and a tremendous man of faith, life will not be the same without him," Young wrote. Woolery, with his matinee idol looks, coiffed hair and ease with witty banter, was inducted into the American TV Game Show Hall of Fame in 2007 and earned a daytime Emmy nomination in 1978. In 1983, Woolery began an 11-year run as host of TV's "Love Connection," for which he coined the phrase, "We'll be back in two minutes and two seconds," a two-fingered signature dubbed the "2 and 2." In 1984, he hosted TV's "Scrabble," simultaneously hosting two game shows on TV until 1990. "Love Connection," which aired long before the dawn of dating apps, had a premise that featured either a single man or single woman who would watch audition tapes of three potential mates and then pick one for a date. A couple of weeks after the date, the guest would sit with Woolery in front of a studio audience and tell everybody about the date. The audience would vote on the three contestants, and if the audience agreed with the guest's choice, "Love Connection" would offer to pay for a second date. Woolery told The Philadelphia Inquirer in 2003 that his favorite set of lovebirds was a man aged 91 and a woman aged 87. "She had so much eye makeup on, she looked like a stolen Corvette. He was so old he said, 'I remember wagon trains.' The poor guy. She took him on a balloon ride." Other career highlights included hosting the shows "Lingo," "Greed" and "The Chuck Woolery Show," as well as hosting the short-lived syndicated revival of "The Dating Game" from 1998 to 2000 and an ill-fated 1991 talk show. In 1992, he played himself in two episodes of TV's "Melrose Place." Woolery became the subject of the Game Show Network's first attempt at a reality show, "Chuck Woolery: Naturally Stoned," which premiered in 2003. It shared the title of the pop song in 1968 by Woolery and his rock group, the Avant-Garde. It lasted six episode and was panned by critics. Woolery began his TV career at a show that has become a mainstay. Although most associated with Pat Sajak and Vanna White, "Wheel of Fortune" debuted Jan. 6, 1975, on NBC with Woolery welcoming contestants and the audience. Woolery, then 33, was trying to make it in Nashville as a singer. "Wheel of Fortune" started life as "Shopper's Bazaar," incorporating Hangman-style puzzles and a roulette wheel. After Woolery appeared on "The Merv Griffin Show" singing "Delta Dawn," Merv Griffin asked him to host the new show with Susan Stafford. "I had an interview that stretched to 15, 20 minutes," Woolery told The New York Times in 2003. "After the show, when Merv asked if I wanted to do a game show, I thought, 'Great, a guy with a bad jacket and an equally bad mustache who doesn't care what you have to say — that's the guy I want to be.'" NBC initially passed, but they retooled it as "Wheel of Fortune" and got the green light. After a few years, Woolery demanded a raise to $500,000 a year, or what host Peter Marshall was making on "Hollywood Squares." Griffin balked and replaced Woolery with weather reporter Pat Sajak. "Both Chuck and Susie did a fine job, and 'Wheel' did well enough on NBC, although it never approached the kind of ratings success that 'Jeopardy!' achieved in its heyday," Griffin said in "Merv: Making the Good Life Last," an autobiography from the 2000s co-written by David Bender. Woolery earned an Emmy nod as host. Born in Ashland, Kentucky, Woolery served in the U.S. Navy before attending college. He played double bass in a folk trio, then formed the psychedelic rock duo The Avant-Garde in 1967 while working as a truck driver to support himself as a musician. The Avant-Garde, which tourbed in a refitted Cadillac hearse, had the Top 40 hit "Naturally Stoned," with Woolery singing, "When I put my mind on you alone/I can get a good sensation/Feel like I'm naturally stoned." After The Avant-Garde broke up, Woolery released his debut solo single "I've Been Wrong" in 1969 and several more singles with Columbia before transitioning to country music by the 1970s. He released two solo singles, "Forgive My Heart" and "Love Me, Love Me." Woolery wrote or co-wrote songs for himself and everyone from Pat Boone to Tammy Wynette. On Wynette's 1971 album "We Sure Can Love Each Other," Woolery wrote "The Joys of Being a Woman" with lyrics including "See our baby on the swing/Hear her laugh, hear her scream." After his TV career ended, Woolery went into podcasting. In an interview with The New York Times, he called himself a gun-rights activist and described himself as a conservative libertarian and constitutionalist. He said he hadn't revealed his politics in liberal Hollywood for fear of retribution. He teamed up with Mark Young in 2014 for the podcast "Blunt Force Truth" and soon became a full supporter of Donald Trump while arguing minorities don't need civil rights and causing a firestorm by tweeting an antisemitic comment linking Soviet Communists to Judaism. "President Obama's popularity is a fantasy only held by him and his dwindling legion of juice-box-drinking, anxiety-dog-hugging, safe-space-hiding snowflakes," he said. Woolery also was active online, retweeting articles from Conservative Brief, insisting Democrats were trying to install a system of Marxism and spreading headlines such as "Impeach him! Devastating photo of Joe Biden leaks." During the early stages of the pandemic, Woolery initially accused medical professionals and Democrats of lying about the virus in an effort to hurt the economy and Trump's chances for reelection to the presidency. "The most outrageous lies are the ones about COVID-19. Everyone is lying. The CDC, media, Democrats, our doctors, not all but most, that we are told to trust. I think it's all about the election and keeping the economy from coming back, which is about the election. I'm sick of it," Woolery wrote in July 2020. Trump retweeted that post to his 83 million followers. By the end of the month, nearly 4.5 million Americans had been infected with COVID-19 and more than 150,000 had died. Just days later, Woolery changed his stance, announcing his son had contracted COVID-19. "To further clarify and add perspective, COVID-19 is real and it is here. My son tested positive for the virus, and I feel for of those suffering and especially for those who have lost loved ones," Woolery posted before his account was deleted. Woolery later explained on his podcast that he never called COVID-19 "a hoax" or said "it's not real," just that "we've been lied to." Woolery also said it was "an honor to have your president retweet what your thoughts are and think it's important enough to do that." In addition to his wife, Woolery is survived by his sons Michael and Sean and his daughter Melissa, Young said.None
I'M A Celebrity fans have spotted a show 'feud' and are convinced Ant McPartlin 'hates' a campmate. The latest episode of ITV jungle reality show aired on Sunday night as Dean McCullough and Coleen Rooney took on the latest trial. But as they arrived at the trial clearing and were greeted by hosts Ant and Dec, Radio 1 star Dean cracked a joke. He said: "Well, well, well. We need to stop meeting like this. I've told you I didn't want another date." As Declan Donnelly laughed, Ant just looked blankly in Dean's direction. The moment didn't go unnoticed as I'm A Celebrity fans flooded social media with their reactions. One said: "Ant hates Dean so much omg his face says it all." A second wrote: "Ant can’t stand Dean you can tell." "Ant literally looks like he hates Dean," a third posted. While a fourth commented: "Ants face when dean said I told you I didn’t want to say." MAURA Higgins is a late entry to I'm A Celeb 2024. Yet who is joining her? 2019 Love Island star Maura, 33, will be a late entry to the jungle line-up. She will head into the I'm A Celeb camp , along with the Reverend Richard Coles , 62. The duo will join the likes of Coleen Rooney , Barry McGuigan and Danny Jones in Ant and Dec’s jungle camp a week into this year’s star-spangled series. Yet initially the duo will have their own private base - and a secret mission - before heading into the main compound Down Under. Maura has already described the jungle as "hell." Meanwhile Richard, who has starred on Strictly, has confessed his biggest "fear."