Tag Archives: IRS

Foreign Tax Credit Refund Claim Denied as Untimely

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Our International Tax Group discusses a recent case that offers a cautionary tale on statutory limitations periods and shows how even seemingly straightforward provisions are open to interpretation. 10 years vs. three years vs. two years? When is a refund “attributable to” foreign taxes? What does it mean to “pay” taxes? Read the full advisory here. [...]Read more

Regulation Confusion

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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

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

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

The Taxman Cometh: IRS Begins Assessing Employer Mandate Penalties

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The IRS begins to enforce the ACA employer mandate. Our Employee Benefits & Executive Compensation Group provides critical information you need now to avoid losing your opportunity to contest an inaccurate assessment. Read the full advisory here. [...]Read more

Qualified Retirement Plan Amendments: Year-End Update

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Our Employee Benefits & Executive Compensation Group reminds plan sponsors to get ready for 2017 IRS year-end amendments.

  • Discretionary amendments
  • Storm and disaster relief
  • Required amendments

Read the full advisory here.

Do You Need to Send an Annual Notice to Plan Participants?

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Our Employee Benefits & Executive Compensation Group reviews the multiple year-end notices that defined contribution plans must issue to participants.

  • 2018 retirement plan limits
  • Special consideration for safe harbor plans
  • Practice pointers

Read the full advisory here.

International Tax ADVISORY: Big Tax Court Win for Eaton in Canceled APA Case

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The IRS abused its discretion when it canceled two advance pricing agreements. Our International Tax Group covers Eaton’s victory in the Tax Court and how it allays concerns about how worthwhile an APA can be. Public and judicial scrutiny Standard of review Where do we go from here? Read the full advisory here. [...]Read more