Search for:

Daniel Hudson

Daniel Hudson — a member of the Firm’s Tax Practice Group in Miami — practices mainly in the areas of international tax planning for multinational entities and high net worth individuals. He has authored several publications for Tax News and Developments and has spoken at Firm-sponsored trainings and conferences on tax issues. Active in the Firm’s pro bono activities, Daniel spearheads Baker McKenzie’s annual visit to the Camillus House Soup Kitchen, where the Firm serves dinner to hundreds of homeless and economically disadvantaged individuals.

On 23 July 2020, the Treasury Department (“Treasury”) and the Internal Revenue Service (“IRS”) published final regulations under Section 951A providing guidance with respect to the high-tax exception, which excepts certain ‘high-taxed’ income from being otherwise taxed as “Global Intangible Low-Tax Income” (“GILTI”). The final regulations maintain the same foreign tax rate threshold to be eligible for a high-taxed income exclusion while simultaneously modifying operational rules that may affect a U.S. individual’s decision to pursue the exclusion. In conjunction with these final regulations, Treasury and the IRS issued new proposed regulations conforming aspects of the Subpart F high-tax exception with the newly finalized GILTI high-tax exception, and providing for a single high-tax exception election under Section 954(b)(4). 

Click here to request the latest edition of this newsletter.  Feature Malaysia: Wealth management and tax planning in the wake of COVID-19 Case Summaries Brazil Private Letter Ruling No. 41 of 31 March 2020 — tax treatment of trust distributions to Brazilian beneficiaries France Wealth tax — The refusal to…