The Treasury Department and the Internal Revenue Service (IRS) issued Notice 2018-26, which provides guidance under section 965 of the Internal Revenue Code regarding the “transition tax.” Section 965 imposes a transition tax...more
4/10/2018
/ Accounting Methods ,
Controlled Foreign Corporations ,
Corporate Taxes ,
Foreign Earned Income ,
Foreign Subsidiaries ,
Income Taxes ,
International Tax Issues ,
IRS ,
Shareholders ,
Subpart F ,
Tax Rates
The Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) released Notice 2018-16 (the Notice) providing additional guidance regarding the transition tax in section 965 of the Internal Revenue Code of...more
4/10/2018
/ Anti-Avoidance ,
Controlled Foreign Corporations ,
Foreign Corporations ,
International Tax Issues ,
IRS ,
Net Operating Losses ,
Offshore Companies ,
Partnerships ,
Pass-Through Entities ,
SFC ,
Shareholders
On December 22, 2017, the President signed into law the bill formerly known as the Tax Cuts and Jobs Act (the Final Bill), which was passed by the House of Representatives and the Senate earlier in the week. The passage of...more
On December 15, 2017, the House-Senate Conference Committee released a revised version of the Tax Cuts and Jobs Act (the Final Bill) that is expected to be passed by the House of Representatives and Senate later this week and...more
On November 16, 2017, the House of Representatives passed a much anticipated tax reform bill, titled the Tax Cuts and Jobs Act (the House Plan), which was first introduced on November 2, 2017. The passage of the House Plan...more
On November 9, 2017, the Senate Finance Committee released a Description of the Chairman’s Mark of the “Tax Cuts and Jobs Act” and on November 14, 2017, the Senate Finance Committee released a Description of the Chairman’s...more
11/20/2017
/ Corporate Taxes ,
Deferred Compensation ,
Employee Benefits ,
Energy Tax Incentives ,
Insurance Industry ,
Legislative Agendas ,
Property Tax ,
Proposed Legislation ,
Tax Deductions ,
Tax Rates ,
Tax Reform ,
Trump Administration
On November 2, 2017, Republicans on the House Ways and Means Committee released their much anticipated tax reform bill, titled the Tax Cuts and Jobs Act (as modified by Chairman Brady on November 3 and November 6, the House...more
On October 2, 2017, the Treasury Department (Treasury) released a report identifying certain significant regulations for full withdrawal, partial revocation or substantial revision and noting that over 200 additional...more
On October 2, 2017, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued Notice 2017-57 (the Notice) announcing that Treasury and the IRS:
- Are considering changes to the final...more
The Internal Revenue Service (IRS) recently released guidance on certain “north-south” spinoff transactions. Generally, a “north-south” transaction consists of a transfer of property from a shareholder to a corporation close...more
Time may be running out for taxpayers to correct technically deficient gain recognition agreements (GRAs) under the relief procedure contained in the Directive on Examination Action With Respect to Certain Gain Recognition...more
On May 7, Treasury and the IRS published proposed regulations addressing which corporation succeeds to the tax attributes of another corporation that transfers assets in an acquisitive asset reorganization described in IRC §§...more
On June 25, the IRS expanded its “no-rule” policy with respect to spin-offs and other tax-free corporate separations, liquidations, contributions, and reorganizations. Effective for letter ruling requests received by the IRS...more
On January 30, Treasury and the IRS issued proposed regulations relating to the proper filing of gain recognition agreements (GRAs) and other related compliance obligations (the Proposed Regulations). As a general matter, a...more