Our Unclaimed Property Team examines the potential adverse impacts on holders as Colorado joins the list of states updating their unclaimed property laws by adopting a version of RUUPA that repeals its existing $25 reporting deduction but preserves the state’s existing treatment of gift cards. Impacted holders should consider redomestication Will the state apply the repeal retroactively and attempt to claw back deducted funds? Gift cards and gift certificates – maintaining the status quo Read the fill advisory here. [...]Read more
Our International Tax Group reflects on a few concerns that have cropped up in the wake of the Tax Cuts and Jobs Act and deciphers the government’s responses. Foreign-derived intangible income (FDII) Global intangible low-taxed income (GILTI) Base erosion and anti-abuse tax (BEAT) Read the full advisory here. [...]Read more
What guidance has the “force and effect of law”? Our Federal Tax Group dives into an appeal of a court case involving Notice 2016-66, the Anti-Injunction Act, and a new Treasury policy statement that could upset the department’s applecart. A new transaction of interest: micro-captive transactions Policy Statement on the Tax Regulatory Process Eviscerating the premise of an argument Read the full advisory here. [...]Read more
Stay engaged with the aftereffects of the Tax Cuts and Jobs Act and the new IRS regulations. Our weekly client update continues with four scheduled sessions. Sign up here. March 19 - Global Intangible Low-Taxed Income (GILTI) March 26 - Notice 2019-1: Previously Taxed Earnings and Profits (PTEP) April 2 - Foreign Tax Credits April 9 - Section 864(c)(8) – Effectively Connected Income and Sales of Partnership Interests In case you missed them, here are links to revisit our previous sessions: State & Local Tax Opportunity Zones Anti-Hybrid Rules Outbound Case [...]Read more
The IRS and Treasury’s proposed regulations on the Section 250 deduction for foreign-derived intangible income (FDII) and global intangible low-taxed income (GILTI) tackle several questions left unanswered by the 2017 tax law. Our International Tax Group highlights key takeaways from the complex, near-algebraic, proposed rules. Section 250 alphabet soup: FDII, GILTI, QBAI, DEI, FDDEI GILTI deduction allowed for Section 962 election taxpayers A few questionable answers for FDII issues Read the full advisory here. [...]Read more
Our Federal Tax Group considers ways to pass the inscrutable device prohibition in the Section 355 rules.
- An “out” from device
- How about a Morris Trust transaction?
- Where does the cash come in?
Read the full advisory here.
At long last, we have the first set of final regulations for the Tax Cuts and Jobs Act. Our International Tax Group celebrates with a look at how the Treasury and IRS have clarified Section 965 and why taxpayers may need to act quickly. The de minimis threshold Exceptions to the anti-abuse rules Transfer agreements and the basis adjustment election Read the full advisory here. [...]Read more
The multistate unclaimed property landscape continued to evolve rapidly in 2018, and we expect more of the same in 2019. Kendall Houghton and Michael Giovannini look at unclaimed property issues in this issue of Retail: What's in Store. Read the publication here. [...]Read more
In case you missed our live broadcast, please check out Scott Harty, Carolyn Smith, Earl Pomeroy, and Jack Cummings as they walk through key elements of the new regulations and address the prospects of technical corrections. Click here to listen. If you are interested in signing up for one of our future weekly webinars covering topics such as section 199A, BEAT, GILTI, foreign tax credits, opportunity zones, or state & local tax, click here. [...]Read more