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
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.
Our Federal Tax Group explains why Section 163(j)’s small business exception is useful, but may not be quite the exemption taxpayers think it should be. “Small business” is a difficult definition Thwarted by the aggregation rule Can you apply the real estate exemption? Read the full advisory here. [...]Read more
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
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