Category Archives: Tax Reform

Omnibus Spending Bill Makes Long-Awaited Technical Corrections to Several PATH Act Provisions

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While the omnibus spending bill didn’t do much to clarify the Tax Cuts and Jobs Act, it did make some corrections to other tax laws. Our International Tax Group discusses some of those corrections for qualified foreign pension funds and the Foreign Investment in Real Property Tax Act of 1980 (FIRPTA). Requirements for qualified foreign pension funds Changes for problematic requirements Corrections to the PATH Act Read the full advisory here.  [...]Read more

Trickle Down Guidance: Interim Notices Tackle Key International Reforms

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The IRS gives taxpayers a bit more direction on two provisions of the Tax Cuts and Jobs Act already in force. Our International Tax Group breaks down the new guidance for the repatriation tax and foreign partner withholding. Notice 2018-26 previews anti-avoidance and other rules under Section 965 Notice 2018-29 moves ahead with withholding for non-publicly traded partnerships under Section 1446(f) Read the full advisory here.  [...]Read more

Foreign-Derived Intangible Income

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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

The Tax Act’s New Business Interest Expense Limitation – Dear IRS: Some Guidance, Please?

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The Tax Cuts and Jobs Act replaced the earnings stripping rules with a new limitation on deductions for business interest expense. Our International Tax Group examines the new law and what it means for interest expense deductions going forward. Special rules for partnerships and S corporations Rules for corporations What the new limitation leaves out Read the full advisory here. [...]Read more

Georgia Proposes Response to Federal Tax Reform

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Almost two months since the President signed the Tax Cuts and Jobs Act (TCJA) into law, state legislators across the country are still evaluating the federal tax law’s effects on state revenues and whether to amend state law in response. Introduced on February 12, Georgia’s Internal Revenue Code conformity bill for the 2018 tax year, HB 918, is one example of how states may respond to federal tax reform. HB 918 conforms to many of the provisions in the TCJA, including the $10,000 state and local tax deduction limitation and the treatment of net operating losses. Like at the federal level, [...]Read more

Inexplicably, Section 956 Survives Tax Reform Intact

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How did a section of the Internal Revenue Code destined for repeal by both the House and Senate versions of the Tax Cuts and Jobs Act survive the final Act? Our International Tax Group examines the future application of Section 956 in the wake of the new tax regime. Section 956’s 50-plus-year history The House and Senate versions Scope of application Read the full advisory here. [...]Read more

International Tax Reform Is Here

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Our International Tax Group reveals how savvy and flexible taxpayers can optimize their tax position in the new landscape created by the Tax Cuts and Jobs Act. New territorial system and mandatory repatriation Anti-base erosion measures Changes to Subpart F and other provisions Click here to read the full advisory. [...]Read more

Tax Reform: Invitation to the Weekly Client Update from Alston & Bird

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With tax reform officially upon us, our subject matter experts will take a deeper dive into areas that are critical to your business, such as corporate taxes, international issues, executive compensation and employee benefits, and partnerships.   The 2018 call-in series will kick off on Tuesday, January 9. All seminars will start at 11am ET and last approximately 30 minutes. Click here to RSVP and receive the dial-in information.   [...]Read more

SEC Staff Provides Guidance on the Tax Accounting Implications of the Tax Cuts and Jobs Act

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Our Securities Group analyzes the Securities and Exchange Commission’s new staff guidance on the accounting impacts U.S. tax reform will have on publicly traded companies and their financial statement disclosures. Staff Accounting Bulletin (SAB) No. 118 SEC Staff Compliance and Disclosure Interpretation (C&DI) 110.02 SEC Consultation Guidance Click here to read the full advisory. [...]Read more