Category Archives: Tax Reform

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

International Tax Reform Is Here

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Our International Tax Group reveals how savvy and flexible taxpayers can optimize their tax position in the new landscape created by the Tax Cuts and Jobs Act. New territorial system and mandatory repatriation Anti-base erosion measures Changes to Subpart F and other provisions Click here to read the full advisory. [...]Read more

Tax Reform: Invitation to the Weekly Client Update from Alston & Bird

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With tax reform officially upon us, our subject matter experts will take a deeper dive into areas that are critical to your business, such as corporate taxes, international issues, executive compensation and employee benefits, and partnerships.   The 2018 call-in series will kick off on Tuesday, January 9. All seminars will start at 11am ET and last approximately 30 minutes. Click here to RSVP and receive the dial-in information.   [...]Read more

SEC Staff Provides Guidance on the Tax Accounting Implications of the Tax Cuts and Jobs Act

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Our Securities Group analyzes the Securities and Exchange Commission’s new staff guidance on the accounting impacts U.S. tax reform will have on publicly traded companies and their financial statement disclosures. Staff Accounting Bulletin (SAB) No. 118 SEC Staff Compliance and Disclosure Interpretation (C&DI) 110.02 SEC Consultation Guidance Click here to read the full advisory. [...]Read more

Tax Act: Vote and Value

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Our Federal Tax Group explains the nuances tax reform brings to the definition of a U.S. shareholder, including a surprise for controlled foreign corporations.

  • U.S. shareholders
  • The vote or value definition
  • Controlled foreign corporations

Click here to read the full advisory.

Senate Passes Tax Cuts and Jobs Act

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The Senate passed the Tax Cuts and Jobs Act in the early morning hours of Saturday, December 2, marking a major legislative win for the Republican majority.  The final vote on passage was 51-49, with Sen. Bob Corker (R-TN) the only Republican vote against, and no Democrats voting for the bill. A manager’s amendment making significant changes to the bill was adopted.  In addition, two other amendments were adopted, one by Sen. Ted Cruz (R-TX) allowing section 529 education plans to be used to pay for K-12 education expenses, including home schooling, and a Democratic amendment by Sen. Jeff [...]Read more

The Republican Tax Reform Framework: What It Says and What It Doesn’t

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Tax reform is coming, and Republican leaders have published a framework that raises as many questions as it answers. Our Tax Policy & Regulation Team investigates what the Big Six reveal and—just as important—what they don’t. Tax rates for corporations and pass-through entities Shifting to a territorial tax system Revenue raisers and budget impact Read the full advisory here. [...]Read more

Tax Change Planning

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With tax cuts likely coming, it might make sense to consider establishing a C corporation for some new businesses. Our Federal Tax Group offers tax planners several different ways of thinking. Tax Reform Act of 1986 Payment of dividends and stock buybacks Less advantageous structures Read the full advisory here. [...]Read more

Information Exchange Under the OECD’s Common Reporting Standard Begins Early in Select Countries

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At the end of the month, dozens of countries will begin exchanging information under the OECD’s Common Reporting Standard as “early adopters.” Our International Tax Group examines the CRS and its relation to FATCA. How does the CRS work? What are the reporting requirements? How will the CRS impact U.S. taxpayers? Read the full advisory here.  [...]Read more