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Tax Policy

Prospects of Technical Corrections in the New Congress

January 24, 2019 By Alston & Bird Tax Team

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

Filed Under: Federal Tax, State & Local Tax, Tax Policy, Tax Reform Tagged With: 199A, BEAT, foreign tax credits, GILTI, opportunity zones

Omnibus Spending Bill Makes Long-Awaited Technical Corrections to Several PATH Act Provisions

May 17, 2018 By Stefanie Kavanagh and James Croker

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

Filed Under: International Tax Advisory, Tax Policy, Tax Reform Tagged With: Consolidated Appropriations Act of 2018, Omnibus, PATH Act, QCIVs, QFPFs, qualified collective investment vehicles, qualified foreign pension funds, Section 199a, Tax Cuts and Jobs Act, tax refrom, TCJA, Trump

Trickle Down Guidance: Interim Notices Tackle Key International Reforms

April 16, 2018 By Edward Tanenbaum and Heather Ripley

The IRS gives taxpayers a bit more direction on two provisions of the Tax Cuts and Jobs Act already in force. Our International Tax Group breaks down the new guidance for the repatriation tax and foreign partner withholding. Notice 2018-26 previews anti-avoidance and other rules under Section 965 Notice 2018-29 moves ahead with withholding for non-publicly traded partnerships under Section 1446(f) Read the full advisory here.  [...]Read more

Filed Under: International Tax Advisory, Tax Policy, Tax Reform Tagged With: Foreign Partners Withholding, IRS, Repartriation Tax, section 965, tax reform, Treasury, Trickle Down Guidance

Foreign-Derived Intangible Income

April 2, 2018 By Jasper L. (Jack) Cummings, Jr.

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

Filed Under: Federal Tax Advisory, Tax Policy, Tax Reform Tagged With: C corporation, CFC, controlled foreign corporation, Corporations, export, Foreign-Derived Intangible Income Deduction

Georgia Proposes Response to Federal Tax Reform

February 19, 2018 By Andrew Yates and Kathleen Cornett

Almost two months since the President signed the Tax Cuts and Jobs Act (TCJA) into law, state legislators across the country are still evaluating the federal tax law’s effects on state revenues and whether to amend state law in response. Introduced on February 12, Georgia’s Internal Revenue Code conformity bill for the 2018 tax year, HB 918, is one example of how states may respond to federal tax reform. HB 918 conforms to many of the provisions in the TCJA, including the $10,000 state and local tax deduction limitation and the treatment of net operating losses. Like at the federal level, [...]Read more

Filed Under: State & Local Tax, State and Local Planning, Tax Policy, Tax Reform

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