On September 9, 2019, the Treasury Department (Treasury) and the Internal Revenue Service (IRS) proposed regulations (proposed regulations) addressing items of income and deduction that are included in the calculation of...more
9/30/2019
/ Acquisitions ,
Built-In Gains ,
Change in Ownership ,
Corporate Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
Loss Limitation Rules ,
Mergers ,
Net Operating Losses ,
Proposed Regulation ,
Section 382 ,
Tax Deductions ,
Tax Planning ,
U.S. Treasury
On December 22, 2017, President Donald Trump signed into law a budget reconciliation act commonly referred to as the Tax Cuts and Jobs Act (TCJA). This sweeping tax bill represents the most comprehensive reform of U.S. tax...more
2/20/2018
/ Anti-Abuse Rule ,
Base Erosion Tax ,
Business Taxes ,
Casualty Insurance ,
Controlled Foreign Corporations ,
Corporate Taxes ,
Foreign Corporations ,
Life Insurance ,
Net Operating Losses ,
Parent Corporation ,
Passive Foreign Investment Company ,
Principle-Based Reserves ,
Property Insurance ,
Tax Cuts and Jobs Act ,
Tax Rates ,
Tax Reform ,
Trump Administration
Recent changes in IRS private letter ruling policy likely will result in greater taxpayer reliance on tax opinions, which may impact certain corporate strategies in the coming year.
Tax-Free Spin-Offs -
During...more