Category Archives: Federal Tax Advisory

Cash Deals Abound

Written by
Cash is king in this year’s M&A deals. Our Federal Tax Group investigates the tax implications behind these all-cash deals and what dangers may lie ahead. Few stocks are held by taxable persons First-step mergers A tax reform revenue raiser that hasn’t raised revenue Read the full advisory here.  [...]Read more

Certain Banks Qualify for the 20% Pass-Through Deduction

Written by

Our Federal Tax Group highlights Section 199A and the IRS’s new proposed regulations that allow pass-through businesses to deduct up to 20% of their qualified business income.

  • Certain banks qualify for the deduction
  • LLCs, partnerships, and S corporations can benefit
  • Only productive businesses can take advantage
  • Anti-abuse rules are built in

Read full advisory here.

Regulation Confusion

Written by
The Office of Management and Budget may throw a wrench into how IRS and Treasury regulations are treated. Our Federal Tax Group outlines why slowing down the regulation process may be the least of taxpayers’ worries. Will the OMB discard traditional distinctions? Legislative vs. interpretive regulations What does it mean for tax reform? Read the full advisory here. [...]Read more

Foreign-Derived Intangible Income

Written by
It’s probably the next-best part of the Tax Cuts and Jobs Act for multinationals. Our Federal Tax Group investigates the foreign-derived intangible income regime and how you can use it. What is an export? Getting the CFC involved Selling a service Read the full advisory here. [...]Read more

Tax Act: Vote and Value

Written by

Our Federal Tax Group explains the nuances tax reform brings to the definition of a U.S. shareholder, including a surprise for controlled foreign corporations.

  • U.S. shareholders
  • The vote or value definition
  • Controlled foreign corporations

Click here to read the full advisory.