Category Archives: Tax Reform

Finally! Final Regulations Published for Section 965 Transition Tax

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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

Prospects of Technical Corrections in the New Congress

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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

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

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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

Trickle Down Guidance: Interim Notices Tackle Key International Reforms

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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

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

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

Tax Reform 2018 – Weekly Client Update from Alston & Bird

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While tax reform worked its way into law, our subject-matter experts took a deeper dive into areas that are critical to our clients businesses. The 16-part teleseminar series covered: Updates from the Hill with Earl Pomeroy, Carolyn Smith, and Scott Harty Year-end filing deadlines with Scott Harty International Tax: Section 965 with Jack Cummings and Scott Harty International Tax (other than Section 965) with Heather Ripley and Scott Harty Executive Compensation  with Carolyn Smith and Mike Stevens Employee Benefits and Health & Welfare with Carolyn Smith and John Hickman [...]Read more

Georgia Proposes Response to Federal Tax Reform

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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

Inexplicably, Section 956 Survives Tax Reform Intact

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How did a section of the Internal Revenue Code destined for repeal by both the House and Senate versions of the Tax Cuts and Jobs Act survive the final Act? Our International Tax Group examines the future application of Section 956 in the wake of the new tax regime. Section 956’s 50-plus-year history The House and Senate versions Scope of application Read the full advisory here. [...]Read more