Tag Archives: TCJA

Qualified Retirement Plan Considerations and 2018 Year-End Action Items

▪ Written by

Our Employee Benefits & Executive Compensation Group reminds plan sponsors to get ready for 2018 IRS year-end amendments and offers year-end action items.

  • Discretionary amendments
  • Storm and disaster relief
  • Tax reform changes

Read the full advisory here.

State of Uncertainty: GILTI Considerations for Individuals

▪ Written by and
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

▪ Written by and
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

▪ Written by
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

▪ Written by and
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