Earlier this week, our International Tax Group analyzed some of the most interesting and significant provisions of the new Treasury and IRS regulations for the base erosion and anti-abuse tax. Clarifications about base erosion payments Clarifications about aggregate groups Election to waive deductions Read the full advisory here. [...]Read more
Recently, a federal appellate court ruled in the ongoing battle between the IRS and taxpayers over the maximum penalty for willfully failing to file an FBAR to report offshore accounts as required under the Bank Secrecy Act. Our International Tax Group discusses: Federal Circuit rules in favor of the IRS, upholding higher statutory ceiling Lower courts have split on the issue What’s next? Read the full advisory here. [...]Read more
Our Employee Benefits & Executive Compensation Group reminds plan sponsors to get ready for 2019 IRS year-end amendments and offers year-end action items. Discretionary amendments Changes to hardship withdrawals Adjustment to the determination letter program Read the full advisory here. [...]Read more
Last week, our Federal Tax Group considered whether corporations that have engaged in spinoffs should be aggressive in deducting expenses.
Read the full advisory here.
The IRS released Proposed Regulations and a Revenue Procedure addressing the Tax Cuts and Jobs Act’s repeal of Section 958(b)(4). Our International Tax Group explores how this guidance affects numerous provisions of the Code. Downward attribution beyond Subpart F, GILTI, and Section 965 Silence on the portfolio interest exemption Safe harbors and eased reporting requirements Read the full advisory here. [...]Read more
Our Employee Benefits & Executive Compensation Group examines the numerous changes – mandatory and permissible – plan sponsors can make to their 401(k) or 403(b) plans in light of new regulations for hardship distributions. When do you need to amend your plan? What are the mandatory and permissible changes? What next steps should you take? Read the full advisory here. [...]Read more
Our Federal Tax Group covers the potential changes to recognizing built-in income in reaction to Treasury proposing new Section 382 regulations with a built-in feature that many will think is a bug. Using the Section 382 deduction limitation Using Section 338 for built-in gains Using the 1374 method for built-in losses Read the full advisory here. [...]Read more
As the computer transactions of the 21st century continue to evolve, our International Tax Group downloads Treasury and the IRS’s attempt at updating the tax implications to keep up. Refreshing the 1998 regulations Classifying cloud transactions Key concerns and looking ahead Read the full advisory here. [...]Read more
Do what Treasury said, not what it says it meant. Earlier this month, our Federal Tax Group explains why the circuit court affirmed one Tax Court decision and reversed another in the name of consistency – and why it means regulation preambles are more important than ever. Affirming in Amazon, reversing in Altera Holding the IRS to literal terms of the regulation Similarity to the Supreme Court ruling on the census citizenship question Read the full advisory here. [...]Read more