Alpha-Numeri-Code
Soft Skills
On The Horizon
I.Y.K.Y.K.
I.C.Y.M.I.
100
IRC § This: Global Intangible Low-Taxed Income Included In Gross Income Of United States Shareholders
What is 951A?
100
"I don't know where I'm going, but I sure know where I've been." Was White Snake singing about this red-lining feature in Word?
What is Track Changes?
100
You might paint it with watercolors, or ride off into it, but this also describes a tax law's expiration date.
What is a sunset?
100
C.A.M.T.
What is Corporate Alternative Minimum Tax?
100
BEAT payments are payments to related foreign parties for which the US party receives a deduction. A de minimis exception says don't worry about your BEAT liability unless you have $500m or more in gross receipts in the prior 3-year period and your this, illustrated above, is at least 3%.
What is Base Erosion Percentage?
200
IRC § This(): Interest -- Limitation on Business Interest
What is 163(j)?
200
Ah, peace and this! Adding this sidebar to your Outlook makes engagement management more manageable.
What is harmon.ie?
200
In 2026, the overall effective tax rate for this type of income will increase from 13.125% to 16.406%. Don't look at me - I'm innocent!
What is GILTI?
200
B.E.P.S.
What is Base Erosion and Profit Shifting?
200
Under Section 174, for specified R&E (research & experimental) expenditures paid or incurred in tax years beginning after December 31, 2021, a taxpayer is allowed an amortization deduction over 5 years for US-situs R&E or over this number of years for non-US-situs R&E.
What is 15?
300
When a CFC distributes previously taxed income, the distribution triggers an FX gain or loss. In general, the IRC § This() gain or loss represents the change in US dollar value of functional currency E&P between the time it was included in income and the time it is distributed.
What is 986(c)?
300
Typing "ctrl + [" will take you to where your formula pulls from, but how do you get back? Use this "fn" key.
What is F5?
300
Alert The Go-Gos! In 2026, "We Got" this rate increasing from 10% to 12.5%.
What is BEAT?
300
F.D.D.E.I.
What is Foreign Derived Deduction Eligible Income?
300
USP sells CFC 1 to a 3rd party in exchange for cash.
Gain, if any, recognized by USP on the sale of CFC 1 is expected to be recharacterized, under this code section, as a deemed dividend to the extent of untaxed E&P attributable to the CFC 1 shares.
What is Section 1248?
400
IRC § This: Deduction For Foreign Source-Portion Of Dividends Received By Domestic Corporations From Specified 10-Percent Owned Foreign Corporations
What is 245A?
400
These are short, 15-minute videos covering ITTS topics to provide updates, overviews, or refreshers. Eat 'em up!
What are Quickbites?
400
This refers to the latest round of the OECD’s two-pillared plan to modify the rules for global attribution of taxing rights over the profits of multinational corporations. The first round was introduced in back in 2015 and 2016.
What is BEPS 2.0?
400
A.T.A.D.
What is the (EU) Anti-Tax Avoidance Directive?
400
CFC 1 sells CFC 2 to a 3rd party in exchange for cash.
Similar to Section 1248, this code section may recharacterize a portion of the gain to the extent of untaxed E&P.
What is Section 964(e)?
500
IRC § This()(): Foreign Base Company Income -- Exception For Certain Income Subject To High Foreign Taxes
What is 954(b)(4)?
500
This, or Westlaw's citation research feature that determines whether a case is good law, makes sure you never miss the "red flags."
What is KeyCite?
500
Also a nickname of rapper Curtis Jackson, the deduction for this type of income is scheduled to decrease from 37.5% to 21.875% in 2026. You can find it in da club with GILTI, incentivizing multinational taxpayers to relocate IP ownership to the US.
What is FDII?
500
I.C.-D.I.S.C.
What is Interest Charge Domestic International Sales Corporation?
500
In the transaction illustrated above, USP is treated as having exchanged CFC 1 stock for (i) CFC 2 stock w/ FMV of 80 in a Section 351 exchange; and (ii) CFC 2's taking on liabilities of 20 in a this section stock sale.
(USP is also treated as having exchanged FDRE's operating assets for CFC 2 stock w/ FMV of 160 and CFC 2's taking on liabilities of 40 in a Section 351 transaction.)
What is 304(a)(1)?