Author Archives: Daniel Reach

Daniel Reach
Danny Reach is an associate in the Federal and International Tax Group. His practice includes federal and international tax planning, and he has particular experience with the tax aspects of derivative financial instruments.  Read More →

Another Chapter in the Effectively Connected Income Saga—IRS Issues Proposed Regulations on Sales of Partnership Interests by Foreign Partners

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The IRS gets granular on new Section 864(c)(8), created by the Tax Cuts and Jobs Act. Our International Tax Group examines the implications of the newest proposed regulations brought on by tax reform. How Section 864(c)(8) codifies longstanding IRS principles on effectively connected income The proposed regulations’ complex formula for deemed partnership asset sales Application to tiered partnerships and treaties Read the full advisory here. [...]Read more

Plot Twist – Proposed Regulations Mean Section 956 Did Not Actually Survive Tax Reform Intact

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Our International Tax Group takes stock of new proposed regulations that try to keep Section 956 relevant despite the Tax Cuts and Jobs Act. Many were left scratching their heads “A result directly at odds with the manifest purpose of Section 956” Impact of the proposed regulations Read the full advisory here. [...]Read more

State of Uncertainty: GILTI Considerations for Individuals

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Our International Tax Group explores the hidden terrain for individuals found in the new tax on global intangible low-taxed income (GILTI). The Section 250 deduction The renewed importance of Section 962 Beware of the C-corp. lobster pot 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

Information Exchange Under the OECD’s Common Reporting Standard Begins Early in Select Countries

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At the end of the month, dozens of countries will begin exchanging information under the OECD’s Common Reporting Standard as “early adopters.” Our International Tax Group examines the CRS and its relation to FATCA. How does the CRS work? What are the reporting requirements? How will the CRS impact U.S. taxpayers? Read the full advisory here.  [...]Read more

International Tax ADVISORY – Trump’s Tax Reform Plan When the Dessert Pays for Dinner

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President Trump is beginning to follow through on Candidate Trump’s promises to overhaul the tax code. Our International Tax Group examines the few details we have and the path any legislation must take to become law.

  • The opening bid
  • Border tax
  • Path through the Senate

Read the full advisory here. 

International Tax Advisory: The PFIC Regulations Get a Facelift

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Our International Tax Group discusses the new rules found in Treasury’s final regulations on passive foreign investment companies.

Read the full advisory by clicking here.

IRS Private Letter Ruling Holds that Pass-Through Interests in Mortgages Can Qualify as Registered Form Obligations

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In late January, the IRS issued a private letter ruling (P.L.R. 201504004) dealing with whether interests in a non-grantor trust and a partnership are considered to be in registered form, a precursor to qualification for payments thereon to the portfolio interest exemption. Although the ruling answers in the affirmative, it does not ultimately state whether the particular payments addressed in the ruling would be eligible for the portfolio interest exemption. To qualify for the portfolio interest exemption, and avoid U.S. withholding tax on payments of U.S.-source interest to a foreign person, [...]Read more