• Skip to primary navigation
  • Skip to main content
  • Skip to primary sidebar
  • Skip to secondary sidebar

Alston & Bird Tax Blog

  • Home
  • Services
  • Contacts

section 965

Down the Rabbit Hole: Guidance Addressing Downward Attribution After Repeal of Section 958(b)(4)

October 15, 2019 By Edward Tanenbaum and Daniel Reach

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

Filed Under: International Tax Advisory Tagged With: 958(b)(4), GILTI, IRS, portfolio interest exemption, proposed regulations, Revenue Procedure, safe harbor, section 965, Subpart F, Tax Cuts and Jobs Act, tax refrom

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

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

International Tax Reform Is Here

January 16, 2018 By Edward Tanenbaum and Scott Harty

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

Filed Under: International - Inbound, International - Outbound, International Tax Advisory, Tax Reform Tagged With: 100% dividends-received deduction, Anti-Hybrid Provisions, Base Erosion and Anti-Abuse Tax, BEAT, FDII, foreign tax credit, Foreign-Derived Intangible Income Deduction, mandatory repatriation tax, section 965, Subpart F, tax reform

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

January 8, 2018 By Alston & Bird Tax Team

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

Filed Under: Corporate - Federal, Corporate - State, Employee Benefits, Federal - Corporate Tax Planning, Federal Tax, Partnerships, Tax Policy, Tax Reform Tagged With: corporate, employee benefits, executive compensation, health & welfare, international tax, partnerships, section 965, Tax, tax reform

Primary Sidebar

As a service of Alston & Bird’s Tax groups, this blog focuses on current issues and events in international, federal, state and local tax and wealth planning of interest to business.

Subscribe

Receive email notifications when new posts are added.

Check your inbox or spam folder to confirm your subscription.

Tags

401(k) ACA Affordable Care Act audit BEAT CARES Act CFC Corporate Tax Planning covid-19 Delaware ERISA Escheat FATCA FBAR FDII Gift cards GILTI international tax IRA IRS Kelmar New York nexus OECD qualified plans Quill RUUPA SCOTUS Section 351 Section 355 Section 367 Section 385 section 482 section 965 State legislation Subpart F Supreme Court Tax Court Tax Cuts and Jobs Act tax reform TCJA Treasury Unclaimed property UP Wayfair

Secondary Sidebar

Categories

Recent Posts

  • PTET Elections: Don’t Let Them “Pass” By Unnoticed in M&A Transactions
  • Post-Roe Issues for Health Plan Sponsors: Navigating the Rapidly Changing Legal Landscape
  • Litigate, Legislate and Repeat: The Delaware Escheat Law Spin Cycle
  • Looking Back at Georgia’s 2022 Legislative Session
  • Diving into IRS’s Annual Report on Advance Pricing Agreements: Can APMA Overcome Its Sisyphean Task?

Archives

Copyright © 2023 · Alston & Bird · All Rights Reserved. Privacy.