Category Archives: Federal Tax Advisory

Sales of CFCs Got Harder?

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Our Federal Tax Group gives a glimpse into the brave new world of selling foreign assets and stock in the wake of the Tax Cuts and Jobs Act.

  • Selling a U.S. sub versus selling a CFC
  • GILTI as a new option over Subpart F
  • Analyzing the options

Read the full advisory here.

GILTI Basis Adjustments

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Our Federal Tax Group explores how Treasury’s proposed regulations could have the global intangible low-taxed income (GILTI) regime operating in a way you might not expect.

Read the full advisory here.

Antique Weapons

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Some antique weapons are still dangerous; Section 269 could be one of them. Our Federal Tax Group explains why taxpayers facing Section 269 on audit should treat it seriously and what it reveals about the IRS’s hand. The three-part test Old, convoluted court opinions Is it as useful as the economic substance doctrine? Read the full advisory here. [...]Read more

Cash Deals Abound

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Cash is king in this year’s M&A deals. Our Federal Tax Group investigates the tax implications behind these all-cash deals and what dangers may lie ahead. Few stocks are held by taxable persons First-step mergers A tax reform revenue raiser that hasn’t raised revenue Read the full advisory here.  [...]Read more

Certain Banks Qualify for the 20% Pass-Through Deduction

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Our Federal Tax Group highlights Section 199A and the IRS’s new proposed regulations that allow pass-through businesses to deduct up to 20% of their qualified business income.

  • Certain banks qualify for the deduction
  • LLCs, partnerships, and S corporations can benefit
  • Only productive businesses can take advantage
  • Anti-abuse rules are built in

Read full advisory here.

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

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