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Tax Reform

What’s Your Source? Proposed Regulations on Sourcing Inventory Sales

April 2, 2020 By Edward Tanenbaum and Heather Ripley

Is your inventory sales income U.S. or foreign source? Well, it depends. In case you missed it, our International Tax Group explores the various sourcing rules the IRS has proposed to sort out possible inconsistencies and overlaps caused by the Tax Cuts and Jobs Act. Place of production now determines source for sales of produced inventory Coordinating Section 863(b) and Section 865 for sales through an office The overlap of Section 865(e)(2) and Section 864(c)(4)(B)(iii) for certain “nonresidents” Read the full advisory here. [...]Read more

Filed Under: International Tax Advisory, Tax Reform Tagged With: IRS, nonresidents, Section 863(b), Section 864(c)(4)(B)(iii, Section 865, Section 865(e)(2), Tax Cuts and Jobs Act, tax reform, TCJA

Downward Stock Attribution for CFC Purposes

April 2, 2020 By Jasper L. (Jack) Cummings, Jr.

Missing piece to CARES? Our Federal Tax Group excavates this missing piece and investigates how it would have restored what was repealed by the Tax Cuts and Jobs Act. Restoration of Section 958(b)(4) New Section 951B A newly minted controlled foreign corporation (CFC) regime Ready full advisory here. [...]Read more

Filed Under: Federal Tax Advisory, Tax Reform Tagged With: CARES Act, CFC, Gross Income of Foreign Controlled United States Shareholders, Section 2209, Section 951B, Senate bill, Tax Cuts and Jobs Act, tax reform, TCJA

Hold Up, Partner: Proposed Regulations Address Withholding on Foreign Partner Dispositions

June 17, 2019 By Edward Tanenbaum and Heather Ripley

Newly proposed regulations expand withholding on foreign partners transferring interests in partnerships who do business in the United States. Our International Tax Group evaluates the tightening reins on exceptions. Notice 2018-29 and other prior Section 1446(f) guidance Modified withholding exceptions in the new regulations Activation of previously suspended PTP and secondary withholding Read the full advisory here. [...]Read more

Filed Under: International Tax Advisory, Tax Reform Tagged With: 1446(f), ECI, effectively connected income, Grecian Magnesite Mining, IRS, qualified notice, section 1146, Section 1446(f), section 864(c)(8), Sectopm 864, Tax Cuts and Jobs Act, tax reform, TCJA, Treasury, withholdings

Finally! Final Regulations Published for Section 965 Transition Tax

February 15, 2019 By Edward Tanenbaum, Jasper L. (Jack) Cummings, Jr. and Stefanie Kavanagh

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

Filed Under: International Tax Advisory, Tax Reform Tagged With: section 965, tax reform

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

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