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Omnibus Spending Bill Makes Long-Awaited Technical Corrections to Several PATH Act Provisions

May 17, 2018 By Stefanie Kavanagh and James Croker

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

Filed Under: International Tax Advisory, Tax Policy, Tax Reform Tagged With: Consolidated Appropriations Act of 2018, Omnibus, PATH Act, QCIVs, QFPFs, qualified collective investment vehicles, qualified foreign pension funds, Section 199a, Tax Cuts and Jobs Act, tax refrom, TCJA, Trump

Tax Policy & Regulation ADVISORY: If Republicans Agree on 80% of Tax Reform, What’s the Other 20%?

August 31, 2017 By Carolyn Smith

Our Tax Policy & Regulation Team explores the uneven terrain unfolding in the tax reform debates, from the debt limit to the deficit to reconciliation. Non-tax issues may impact tax reform One of the most fundamental issues for tax reform Adding to the uncertainty Read the full advisory here. [...]Read more

Filed Under: Tax Policy Tagged With: ACA, Affordable Care Act, budget reconciliation, pence, senate finance committee, tax reform, Trump

Federal & International Tax ADVISORY: Big Tax Court Win for Foreign Investors in U.S. Partnerships

July 24, 2017 By Edward Tanenbaum, Andy Immerman, Stefanie Kavanagh and Scott Harty

Our Federal & International Tax Group examines the long-awaited decision in Grecian Magnesite Mining, Industrial & Shipping Co., SA v. Commissioner. While a win for foreign investors in U.S. partnerships, it may not be the final word. Repudiates decades-long position of IRS May have a real impact on U.S. foreign investment May not be the last word on the subject Read the full advisory here. [...]Read more

Filed Under: Federal Tax Advisory, International Tax Advisory Tagged With: aggregate, Department of Treasury, entity, foreign investor, Grecian Magnesite Mining, INdustrial & Shipping Co., IRS, Obama Administration, Rev. Rul 91-32, SA, Section 741, Treasury, Trump, v. Commissioner

International Tax ADVISORY – Trump’s Tax Reform Plan When the Dessert Pays for Dinner

May 15, 2017 By Daniel Reach and Edward Tanenbaum

President Trump is beginning to follow through on Candidate Trump’s promises to overhaul the tax code. Our International Tax Group examines the few details we have and the path any legislation must take to become law.

  • The opening bid
  • Border tax
  • Path through the Senate

Read the full advisory here. 

Filed Under: International Tax Advisory Tagged With: ACA, Affordable Care Act, alternative minimum tax, amt, medicare, Obamacare, reciprocal tax, tax reform, Trump, Trump Tax Reform

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