New GILTI guidance specifies that companies must allocate only half of certain domestic expenses to foreign subsidiaries.

For many businesses that have been “getting away with murder” for years, OECD crackdown is prompting shift of subsidiaries from zero-tax to low-tax jurisdictions.

For many companies, it still makes sense to stash intellectual property in lower-tax jurisdictions overseas.

Rule change would be a boon to tech and pharma companies.

President Trump predicts that $4 trillion will return to the U.S. Few external observers expect repatriations to come anywhere close to that number.

Corporate America remains “in limbo” as IRS punts on foreign tax issue.

Companies that overpaid taxes on offshore profits want flexibility in how they use those funds.

IRS proposed regulations help corporate America make better cash repatriation decisions.