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New Tax Law May Reduce Tax Benefit for Cross-Border Affiliated Insurance/Reinsurance Premiums

On December 22, 2017, the President signed into law H.R. 1, known generally as the Tax Cuts and Jobs Act (the “TCJA”), which makes widespread changes to the Internal Revenue Code. The TCJA includes a number of provisions that...more

Tracking Tax Reform: The Impact on MLPs of the House and Senate Conference Report on the Tax Cut and Jobs Act

On December 15, the House and Senate Conference Committee released the conference report on the Tax Cuts and Jobs Act (the “Conference Committee Report” or “Report”), containing the specific details on the tax plan they hope...more

Tracking Tax Reform: The House and Senate Conference Committee’s Conference Report on the Tax Cuts and Jobs Act

On December 15, the House and Senate Conference Committee released the conference report on the Tax Cuts and Jobs Act (the “Conference Committee Report” or “Report”), containing the specific details on the tax plan they hope...more

Tracking Tax Reform: Comparison of the Tax Cuts and Jobs Act as Passed by the House and Approved by the Senate Finance Committee

On November 16, the House passed the Tax Cuts and Jobs Act (the “House Bill”) by a 227-205 vote. Also on November 16, members of the Senate Finance Committee voted 14-12 to approve their own tax bill (the “Senate Plan”). The...more

The Proposed Tax Cuts and Jobs Act and MLPs

On November 2, the House Ways and Means Committee released the Tax Cuts and Jobs Act (the “Act”). The Act is over 400 pages and was accompanied by a section-by-section summary that itself reached 82 pages. The Act is aimed at...more

Tracking Tax Reform: The Tax Cuts and Jobs Act

On November 2, the House Ways and Means Committee released the Tax Cuts and Jobs Act (the “Act”). The Act differs from the “Unified Framework for Fixing Our Broken Tax Code” (hereinafter referred to as the “Big Six Framework”...more

Tracking Tax Reform: Fall 2017 Update

On September 27 the “Big Six,” which includes Treasury Secretary Steven Mnuchin, National Economic Council Director Gary Cohn, and other top Republicans in the House and Senate, released the “Unified Framework for Fixing Our...more

UPDATE: Massachusetts Department of Revenue Releases Proposed Regulation Requiring Large Out-of-State Internet Vendors to Collect...

Our previous QuickStudy published on July 14, 2017, discussed the swift revocation of Directive 17-1 by the Massachusetts Department of Revenue (“DOR”) following a ruling from the Massachusetts Superior Court that Directive...more

UPDATE: Massachusetts Department of Revenue Revokes Directive Requiring Large Out-of-State Internet Vendors to Collect...

Our previous QuickStudy published on April 14, 2017, detailed Directive 17-1, issued by the Massachusetts Department of Revenue (“DOR”), which would have required all out-of-state internet vendors that in the prior taxable...more

Proposed Regulations Re-Released for Centralized Partnership Audit Rules

New partnership audit rules enacted into law on November 2, 2015 (the “Centralized Partnership Audit Rules”) (previously discussed in our QuickStudy: Bipartisan Budget Act of 2015 Changes Audit Rules for Private Equity and...more

Locke Lord Article: Tracking Tax Reform

On April 26, 2017, Treasury Secretary Steven Mnuchin and White House chief economic advisor Gary Cohn announced President Trump’s latest tax reform proposals, titled “2017 Tax Reform for Economic Growth and American Jobs” and...more

Massachusetts Department of Revenue Adopts a Novel Administrative Position Requiring Large Out-of-State Internet Vendors To...

According to new Directive 17-1 issued by the Massachusetts Department of Revenue, beginning July 1, 2017, all out-of-state internet vendors that in the prior taxable year had greater than $500,000 in Massachusetts sales and...more

Locke Lord Article: Tracking Tax Reform

With the recent release and subsequent quick defeat of the American Health Care Act (AHCA), healthcare reform dominated the news and tax reform was waiting for its turn in the spotlight. Tax reform was a major issue on the...more

Captive Insurance Arrangements Taking Advantage of Section 831(b) Election May Be Required to Report to the IRS

The Internal Revenue Service on November 1, 2016 issued Notice 2016-66 (the Notice) requiring information reporting with respect to certain insurance or reinsurance transactions (often referred to as micro-captive...more

New Regulations for Partnerships Electing into New Partnership Audit Rules Early

New partnership audit rules enacted into law on November 2, 2015 (the “New Partnership Audit Rules”) generally call for all determinations of adjustments to income and payments of tax pursuant to a partnership tax audit,...more

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