Tag Archives: Tax Cuts and Jobs Act

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

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

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

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

Tax Act: Vote and Value

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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.