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U.S.-Chile Income Tax Treaty Enters Into Force

On December 19, 2023, the U.S. Treasury Department (“Treasury”) announced the entry into force of the U.S.-Chile Income Tax Treaty (the “Treaty”). The Treaty provides for reduced withholding tax rates on income such as...more

The Book Minimum Tax, Pillar 2 and Creditable Foreign Income Taxes

As discussed in our alert earlier this week, the recently announced proposed reconciliation package—the Inflation Reduction Act of 2022, H.R. 5376 (the “Bill”)—would impose a new 15% minimum tax on the adjusted financial...more

Inflation Reduction Act of 2022: New Corporate Book Minimum Tax and Changes for Carried Interests

On July 27, 2022, Senators Manchin and Schumer announced that they agreed to a proposed reconciliation package, the Inflation Reduction Act of 2022, H.R. 5376 (the “Bill”). If enacted, the Bill would finance climate programs,...more

IRS Issues Guidance on Interaction of Net Operating Loss and Alternative Minimum Tax Rules

On May 27, 2020, the U.S. Internal Revenue Service (the IRS) published guidance (the Guidance) regarding the interaction of the five-year net operating loss (NOL) carryback rules under the Coronavirus Aid, Relief and Economic...more

IRS Extends Tax Filing And Payment Deadline To July 15, 2020

On March 18, 2020, the IRS issued Notice 2020-17 announcing the extension of the due date for the payment of federal income taxes due April 15, 2020 until July 15, 2020, with no interest, penalties or additions to tax...more

IRS Issues Guidance Regarding Extension of Tax Payment Deadline

On March 18, 2020, the IRS issued Notice 2020-17 announcing the extension of the due date for the payment of federal income taxes due April 15, 2020 until July 15, 2020, with no interest, penalties or additions to tax...more

Section 385 Treasury Regulations Developments

Related Party Debt Documentation Rules Are Removed and Future Changes to Limit Recharacterization Rules Are Expected - On October 31, 2019, the Treasury Department and the Internal Revenue Service (IRS) made two significant...more

Guidance on CFC ‘Downward Attribution Rules’ Provides Limited Relief to US Taxpayers

On October 1, 2019, the Internal Revenue Service (IRS) issued Revenue Procedure 2019-40 (Revenue Procedure) and proposed regulations (Proposed Regulations) addressing issues related to the repeal of section 958(b)(4) by the...more

Final GILTI Regulations and Proposed Regulations on Subpart F Income and GILTI Bring Relief to Private Equity and Other...

On June 14, 2019, the IRS and Treasury finalized the global intangible low-taxed income (GILTI) regulations (T.D. 9866) and issued proposed regulations (REG-101828-19) that will provide significant relief to investors in...more

Tax Cuts and Jobs Act: House and Senate Pass Tax Reform Bill

On December 19, 2017, the Senate passed the “Tax Cuts and Jobs Act of 2017” (H.R. 1) (the “Bill”). The House of Representatives passed the Bill on December 20, 2017. This follows the release by the conference committee of the...more

House Committee on Ways and Means Releases Tax Reform Proposal

The House Committee on Ways and Means released today its proposed legislative language (the “House Proposal”) implementing, in large part, the framework for tax reform issued by the so-called “Big Six” on September 27, 2017....more

Trump Administration and Congressional Leaders Release Tax Reform Framework

On September 27, 2017, the Trump Administration, the House Committee on Ways and Means and the Senate Committee on Finance released their much-anticipated framework for tax reform (the “Framework”). The Framework generally...more

The US Tax Court Rejects IRS Position That Non-US Partners Are Taxed on Sales of Partnership Interests

The US Tax Court earlier this month issued a decision that rejected a 25-year old IRS Revenue Ruling and held that gain from the sale or other disposition by a non-US person of an interest in a partnership that is engaged in...more

Update on US Federal Tax Reform Proposals

On April 26, the Trump Administration made its much-anticipated release of several “core principles” of its tax plan. In doing so, the administration affirmed its desire to enact comprehensive corporate and individual tax...more

Potential US Tax Reform Could Fundamentally Change the Structure of the US Tax System

With the election of Donald Trump, who pledged during the campaign to usher in fundamental tax reform (including major tax cuts), the Republican majorities in Congress have begun planning major tax changes to the Internal...more

Revival of REIT Rulings Could Mean Good News for Companies with Non-Traditional Assets Considering Becoming REITs

In recent years, there has been a considerable expansion of the types of companies holding non-traditional real estate assets that have elected to become real estate investment trusts for US federal income tax purposes...more

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