Tag Archives: Tax Cuts and Jobs Act

Another Chapter in the Effectively Connected Income Saga—IRS Issues Proposed Regulations on Sales of Partnership Interests by Foreign Partners

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The IRS gets granular on new Section 864(c)(8), created by the Tax Cuts and Jobs Act. Our International Tax Group examines the implications of the newest proposed regulations brought on by tax reform. How Section 864(c)(8) codifies longstanding IRS principles on effectively connected income The proposed regulations’ complex formula for deemed partnership asset sales Application to tiered partnerships and treaties Read the full advisory here. [...]Read more

TCJA Proposed Regulations – Weekly Client Update | 163(j) Interest Deductibility

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Over the next few weeks, we will be hosting weekly 30 minute webinars where our attorneys will walk through key elements of the new TCJA regulations packages, addressing corporate and international issues and state tax matters.

The first session occurs January 15 at 11am when Jack Cummings and Scott Harty walk through key elements of 163(j) interest deductibility.

Click here to sign up and learn more.

State Guidance Needed After Treasury Issues Proposed Regulations Under Section 163(j)

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Our State & Local Tax Group examines why proposed federal regulations for the new interest expense limitation complicates matters for state tax purposes. Not every state follows the new Section 163(j) Federal deduction determined on a consolidated basis … … But states are all over the place Read the full advisory here. [...]Read more

Sales of CFCs Got Harder?

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Our Federal Tax Group gives a glimpse into the brave new world of selling foreign assets and stock in the wake of the Tax Cuts and Jobs Act.

  • Selling a U.S. sub versus selling a CFC
  • GILTI as a new option over Subpart F
  • Analyzing the options

Read the full advisory here.

Plot Twist – Proposed Regulations Mean Section 956 Did Not Actually Survive Tax Reform Intact

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Our International Tax Group takes stock of new proposed regulations that try to keep Section 956 relevant despite the Tax Cuts and Jobs Act. Many were left scratching their heads “A result directly at odds with the manifest purpose of Section 956” Impact of the proposed regulations Read the full advisory here. [...]Read more

State of Uncertainty: GILTI Considerations for Individuals

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Our International Tax Group explores the hidden terrain for individuals found in the new tax on global intangible low-taxed income (GILTI). The Section 250 deduction The renewed importance of Section 962 Beware of the C-corp. lobster pot Read the full advisory here. [...]Read more

First Round of Proposed GILTI Regulations Avoids the Hard(er) Stuff

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The IRS’s opening salvo of proposed regulations under the Tax Cuts and Jobs Act’s global intangible low-taxed income is as complex as you would think. Our International Tax Group cuts through the clutter to address the key takeaways: Computation of GILTI inclusion Anti-abuse rules GILTI guidance still to come Read the full advisory here.  [...]Read more

Cash Deals Abound

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Cash is king in this year’s M&A deals. Our Federal Tax Group investigates the tax implications behind these all-cash deals and what dangers may lie ahead. Few stocks are held by taxable persons First-step mergers A tax reform revenue raiser that hasn’t raised revenue Read the full advisory 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

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