Latest news with #CFC
Hans India
4 days ago
- Business
- Hans India
Mangalagiri Gems Park to be nation's best: Lokesh
Vijayawada: Minister for education, IT, and electronics Nara Lokesh has directed officials to develop the Mangalagiri Gems & Jewellery Park as the best such facility in the country. During a review meeting on the progress of project with officials at Mangalagiri on Thursday, he emphasised the need to expedite the completion of the park and the Common Facility Centre (CFC), which is being supported by the central government. Lokesh instructed officials to ensure that the CFC provides world-class training in jewellery manufacturing and to attract the top 20 jewellery companies in India to set up their manufacturing units and retail outlets in the park. He also suggested studying the operations of the Indian Institute of Gems & Jewellery (IIGJ) in Udupi as a benchmark for the project. APSSDC CEO Ganesh Kumar shared that the CFC and the upcoming Center of Excellence will provide training for 4,000 individuals annually. The park will feature multiple zones, including a Center of Excellence, Common Facility Centre, Industrial, Commercial and Retail Zone, Manufacturing Zone, Residential Zone and Infrastructure Zone. Additionally, Lokesh directed officials to establish a Model Career Centre (MCC) in Mangalagiri at the earliest to provide local youth with skill training, career coaching, job placement assistance, and employer engagement programs. He stressed the importance of empowering youth through structured support. Officials reported that 1,170 youth participated in three job fairs held in Mangalagiri, with 453 securing employment. In response, Lokesh instructed that monthly job fairs be organized to ensure maximum employment opportunities for local youth. The meeting was attended by executive director K Raghu, associate director Purushottam, and other officials.
Forbes
7 days ago
- Business
- Forbes
OBBBA Revises Existing GILTI Tax Rules For U.S. Shareholders Of CFCs
WASHINGTON, DC - JULY 04: U.S. President Donald Trump, joined by Republican lawmakers, signs the ... More One, Big Beautiful Bill Act into law during an Independence Day military family picnic on the South Lawn of the White House on July 04, 2025 in Washington, DC. After weeks of negotiations with Republican holdouts Congress passed the One, Big Beautiful Bill Act into law, President Trump's signature tax and spending bill. The bill makes permanent President Donald Trump's 2017 tax cuts, increase spending on defense and immigration enforcement and temporarily cut taxes on tips, while cutting funding for Medicaid, food assistance and other social safety net programs. (Photo by) On July 4, 2025, President Trump signed into law Pub. L. No. 119-21, also known as the 'One Big Beautiful Bill Act' or 'OBBBA'. The OBBBA makes substantial revisions to many parts of the Internal Revenue Code of 1986, as amended (the 'Code'), including notable changes to the existing Global Intangible Low-Tax Income ('GILTI') inclusion rules. These revisions are discussed more below. The GILTI Regime Prior to the enactment of the Tax Cuts and Jobs Act of 2017 ('TCJA'), many U.S. shareholders with interests in controlled foreign corporations ('CFCs') enjoyed income tax deferral on the CFC's non-passive or 'active' trade or business income. Instead of paying income tax on the CFC's business income each year, U.S. shareholders paid income tax only when the funds earned from the CFC's business were repatriated to them in the form of a dividend. The TCJA modified the deferral rules, requiring U.S. shareholders to report most active business income of a CFC as a GILTI inclusion (regardless of whether the funds are repatriated to the U.S.). Section 951A of the Code contains the GILTI inclusion rules. The provision is complex and chock full of statutory definitions and exclusions. At its basics, U.S. shareholders of a CFC include GILTI as income based on the CFC's 'tested income' with certain deductions. In turn, tested income is defined broadly to include most types of active business income earned overseas that are not already subject to U.S. income tax (e.g., tested income excludes subpart F income and income that is effectively connected with a U.S. trade or business). The current GILTI regime includes two significant reductions to the GILTI inclusion. First, a U.S. shareholder may reduce the GILTI inclusion by a 'net deemed tangible income return' or 'NDTIR.' Very generally, shareholders compute their NDTIR as 10% of the shareholder's allocable share of 'qualified business asset investment,' i.e., the CFC's depreciable trade or business assets. Second, a U.S. shareholder who is a domestic corporation or an individual who has made a valid election to be treated as a domestic corporation under Code section 962 may receive an additional GILTI deduction under Code section 250. For the 2025 tax year, the Code section 250 deduction is 50% of the GILTI inclusion. Prior to enactment of the OBBBA, this 50% rate was scheduled to be reduced to 37.5% starting in the 2026 tax year. Example: Domestic Corporation ('DC') owns 100% of Foreign Corporation ('FC'), a CFC. In 2023, FC earned $1 million of trade or business income from non-passive activities outside the U.S. Also in 2023, FC had an average quarterly qualified business asset investment of $500,000. To compute the GILTI inclusion, DC starts with the $1 million of active trade or business income and reduces that amount by the NDTIR, which is 10% of $500,000, or $50,000. With the 50% section 250 deduction of $475,000 ($950,000 x 50%), DC has a GILTI inclusion of $475,000. With current corporate tax rates of 21%, DC must pay U.S. tax of $99,750 with respect to the GILTI inclusion. OBBBA's GILTI Revisions The OBBBA makes several important revisions to the existing GILTI regime. As an initial matter, it eliminates the GILTI inclusion reduction for NDTIR and renames the GILTI inclusion 'Net CFC Tested Income.' Because foreign corporations no longer receive a NDTIR for eligible depreciable assets, U.S. shareholders should be mindful of the potential tax increases in 2026 when the OBBBA provisions become effective. Although the removal of the NDTIR may increase some U.S. shareholders' Net CFC Tested Income, there are some taxpayer-friendly rules in the OBBBA. As mentioned previously, the Code section 250 deduction—currently 50% of the GILTI inclusion—was scheduled for a reduction of 37.5% in 2026. Under the OBBBA, the Code section 250 deduction is revised to 40% without any further reductions planned in the immediate future. Example: Same facts as the example above except DC and FC are now subject to the OBBBA. With the removal of the NDTIR, DC may no longer claim a reduction in GILTI of $50,000 for FC's qualified business asset investment. In addition, DC's section 250 deduction is now 40% of the Net CFC Tested Income, or $400,000. Accordingly, DC must pay income tax of $126,000 (i.e., 21% of $600,000). OBBBA's Foreign Tax Credit Revisions Foreign tax credits often mitigate the U.S. income tax consequences of foreign business activities. Under GILTI, a U.S. corporate shareholder (or an individual shareholder who made a Code section 962 election) can claim deemed foreign tax credits against U.S. income taxes associated with the GILTI inclusion. However, GILTI limited the allowable foreign tax credits to 80% of the foreign taxes associated with the inclusion (subject to an income gross up). The OBBBA also permits U.S. corporate shareholders (or individual shareholders with a Code section 962 election) to claim a deemed foreign tax credit with respect to the Net CFC Tested Income amounts. However, the OBBBA permits these shareholders to claim an increased 90% of the foreign taxes allocable to the income. Summary The U.S. tax rules associated with CFCs are complex and nuanced (e.g., the IRS Form 5471 filing obligation). Because these rules will change for the 2026 tax year, U.S. shareholders with interests in CFCs should consult with their tax advisors to determine the impact of the changes on their unique tax circumstances.
Yahoo
21-07-2025
- Business
- Yahoo
Cyber insurer CFC weighs potential UK listing with £5bn valuation
Cyber insurance company CFC is in the process of evaluating options including a potential UK listing at a valuation of more than £5bn ($6.74bn), reported the Financial Times. Owned by private equity firms EQT and Vitruvian Partners, CFC is in discussions with investment bankers over potential avenues such as a sale or an initial public offering (IPO). However, sources close to the matter have indicated that no definitive decisions have been made at this point. CFC, a London-based company specialising in cyber insurance, is also contemplating listing on alternative exchanges, including those in the US. These considerations are still in the preliminary stages, and any potential deal is not expected to materialise before the latter half of next year, the report said. The company, which was valued at just over £2.5bn following EQT and Vitruvian's investment in 2021, operates as a managing general agent (MGA). Originally established as CFC has diversified its offerings to include insurance products that protect companies against a wide array of risks such as medical malpractice and product recall. The group has recently completed a significant debt refinancing of $1.7bn and has developed an insurance service for small businesses involved in mergers and acquisitions. With an expansion into more than 20 specialist insurance classes, CFC now operates nine offices worldwide and employs more than 950 individuals. The company's customer base has grown to approximately 150,000, as stated on its website. Last month, CFC appointed Nick Line as its new chief underwriting officer (CUO). Line will join CFC in 2026 following a 28-year tenure at Markel, where he has served as CUO since 2018. Line began working in the insurance industry in 1997, serving in roles such as chief actuary and CUO. "Cyber insurer CFC weighs potential UK listing with £5bn valuation " was originally created and published by Life Insurance International, a GlobalData owned brand. The information on this site has been included in good faith for general informational purposes only. It is not intended to amount to advice on which you should rely, and we give no representation, warranty or guarantee, whether express or implied as to its accuracy or completeness. You must obtain professional or specialist advice before taking, or refraining from, any action on the basis of the content on our site. Sign in to access your portfolio
Daily Mail
18-07-2025
- Business
- Daily Mail
Private equity-backed insurance firm CFC eyes City float
Private equity-backed insurer CFC is eyeing a £5billion London listing – lifting a market which has suffered a mass exodus. The firm, owned by EQT and Vitruvian Partners, is said to be in talks with bankers over options, which could include a sale or an initial public offering. There have been just nine listings in London this year. Three were on the main market and six on AIM. The listings raised just £182.8m – a 64 per cent drop from the same period a year ago, according to analysts. CFC, a cyber security insurance specialist, was bought by Swedish giant EQT and investment firm Vitruvian for £2.5billion in 2021. A London float is being considered, according to the Financial Times, with rival New York also on the table. Talks are in the early stages, say reports.
Zawya
18-07-2025
- Business
- Zawya
Insurer CFC mulls $6.5bln-plus London listing, FT reports
Specialist insurance provider CFC, backed by private equity firms EQT and Vitruvian Partners, is exploring a UK listing that could value the firm at more than 5 billion pounds ($6.71 billion), the Financial Times reported on Friday. The insurer is also considering other options, including a listing in the U.S. or even a sale, the report said, citing people familiar with the matter. Discussions are still in early stages, and any deal was unlikely before the second half of 2026, they added. CFC declined to comment on the report. The two European private equity firms made a "significant" investment in CFC in 2021, valuing the London-based firm at more than 2.5 billion pounds at the time. Founded in 1999 as a cyber insurance provider, CFC has since expanded into more than 20 specialist insurance classes, its website said. The firm operates nine offices globally, with more than 950 employees serving roughly 150,000 customers. CFC's listing could breathe fresh life into London's IPO market, which has been hit by a string of delistings and IPO departures in recent years, with fast-fashion major Shein being the latest to walk away. The UK has been trying to make London a more attractive destination for companies to list and raise funds, and has made major changes to its listing rules last year. ($1 = 0.7448 pounds) (Reporting by Kanjyik Ghosh in Bengaluru; Editing by Sumana Nandy and Rashmi Aich)
