The Bracewell Tax Report is a periodic publication focused on developments in federal income tax law, including the recently enacted Tax Cuts and Jobs Act, with emphasis on how such developments impact the energy, technology...more
9/12/2018
/ Acquisitions ,
Bonus Depreciation ,
Corporate Taxes ,
Energy Sector ,
International Tax Issues ,
IRS ,
MACRS ,
Property Tax ,
Proposed Regulation ,
Public Comment ,
Tax Cuts and Jobs Act ,
Tax Deductions
On August 3, 2018, the IRS and Treasury Department released proposed regulations (the Proposed Regulations) that interpret and clarify the new bonus depreciation regime under the Tax Cuts and Jobs Act (TCJA). The TCJA...more
9/4/2018
/ Acquisitions ,
Arms Length Transactions ,
Bonus Depreciation ,
Corporate Taxes ,
International Tax Issues ,
IRS ,
MACRS ,
Partnerships ,
Pass-Through Entities ,
Proposed Regulation ,
Public Comment ,
Tax Cuts and Jobs Act ,
Tax Deductions
The Bracewell Tax Report is a periodic publication focused on developments in federal income tax law, including the recently enacted Tax Cuts and Jobs Act, with emphasis on how such developments impact the energy, technology...more
8/31/2018
/ Acquisitions ,
Bonus Depreciation ,
Construction Industry ,
Corporate Taxes ,
Internal Revenue Code (IRC) ,
International Tax Issues ,
IRS ,
MACRS ,
Pass-Through Entities ,
Proposed Regulation ,
Public Comment ,
Tax Cuts and Jobs Act ,
Tax Deductions
The Bracewell Tax Report is a periodic publication focused on developments in federal income tax law, including the recently enacted Tax Cuts and Jobs Act, with emphasis on how such developments impact the energy, technology...more
5/3/2018
/ Audits ,
Base Erosion Tax ,
Business Taxes ,
Corporate Taxes ,
Foreign Derived Intangible Income (FDII) ,
Foreign Investment ,
GILTI tax ,
Income Taxes ,
International Tax Issues ,
IRS ,
New Rules ,
Partnership Agreements ,
Partnerships ,
Private Equity Funds ,
Reporting Requirements ,
Tax Cuts and Jobs Act ,
Tax Rates ,
Tax Reform ,
TEFRA
The Bracewell Tax Report is a periodic publication focused on developments in federal income tax law, including the recently enacted Tax Cuts and Jobs Act, with emphasis on how such developments impact the energy, technology...more
4/17/2018
/ Bi-Partison Balanced Budget Act (BBA) ,
Corporate Taxes ,
Energy Sector ,
FCC ,
FIRPTA ,
Foreign Investment ,
Income Taxes ,
International Tax Issues ,
IRS ,
Like Kind Exchanges ,
Loss-Carryover ,
Net Operating Losses ,
New Rules ,
Opt-Outs ,
Partnership Agreements ,
Partnerships ,
Push-Out Requirements ,
Tax Audits ,
Tax Cuts and Jobs Act
The Bracewell Tax Report is a periodic publication focused on developments in federal income tax law, including the recently enacted Tax Cuts and Jobs Act (TCJA), with emphasis on how such developments impact the energy,...more
3/16/2018
/ Base Erosion Tax ,
C-Corporation ,
Capital Gains ,
Corporate Taxes ,
Energy Sector ,
GILTI tax ,
Holding Periods ,
International Tax Issues ,
Pass-Through Entities ,
S-Corporation ,
Tax Cuts and Jobs Act ,
Tax Deductions ,
Tax Rates
The Bracewell Tax Report is a periodic publication focused on developments in federal income tax law, including the recently enacted Tax Cuts and Jobs Act (TCJA), with emphasis on how such developments impact the energy,...more
3/1/2018
/ Audits ,
Corporate Taxes ,
Energy Projects ,
Energy Sector ,
FIRPTA ,
Foreign Investment ,
Foreign Partner ,
Income Taxes ,
Internal Revenue Code (IRC) ,
International Tax Issues ,
IRS ,
New Rules ,
Partnership Agreements ,
Partnerships ,
Renewable Energy ,
S-Corporation ,
Tax Cuts and Jobs Act ,
Tax Planning ,
Tax Rates ,
TEFRA ,
Underpayment
The Tax Cuts and Jobs Act (TCJA) effected sweeping reform across the Internal Revenue Code. This report, and future installments, will discuss this legislation and other important tax guidance, including how such authorities...more
2/16/2018
/ Base Erosion Tax ,
Corporate Taxes ,
Energy Sector ,
Holding Periods ,
International Tax Issues ,
IRS ,
Partnerships ,
REIT ,
Renewable Energy ,
S-Corporation ,
Tax Cuts and Jobs Act ,
Tax Rates ,
Tax Reform
In Grecian Magnesite Mining v. Commissioner (“Grecian Magnesite”) the Tax Court held that a non-U.S. partner's gain from the redemption of its partnership interest was neither U.S. source income nor income effectively...more
8/8/2017
/ Business Taxes ,
FIRPTA ,
Foreign Partner ,
Income Taxes ,
International Tax Issues ,
IRS ,
Non-US Entities ,
Partnership Interests ,
Partnerships ,
Tax Court ,
Tax Liability