Martin Hamilton

Martin Hamilton

Proskauer Rose LLP

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U.S. Tax Reform: IRS Proposes Interest Deduction Limitation Regulations

On November 26, 2018, the Internal Revenue Service (the “IRS”) and the U.S. Department of the Treasury (the “Treasury”) issued proposed regulations (the “Proposed Regulations”) under section 163(j) of the Internal Revenue...more

12/6/2018  /  Anti-Abuse Rule , Business Taxes , C-Corporation , Controlled Foreign Corporations , GILTI tax , Income Taxes , Internal Revenue Code (IRC) , IRS , Partnerships , PFIC , Proposed Regulation , REIT , REMIC , Tax Deductions , Tax Planning , U.S. Treasury

House of Representatives and Senate Conferees Reach Agreement on the Tax Cuts and Jobs Act (H.R. 1): Description of the Conference...

On Friday, December 15, the U.S. House of Representative and Senate conferees reached agreement on the Tax Cuts and Jobs Act (H.R. 1) (the “Final Bill”), and released legislative text, an explanation, and the Joint Committee...more

12/19/2017  /  501(c)(3) , Affordable Care Act , Alternative Minimum Tax , Base Erosion Tax , Controlled Foreign Corporations , Corporate Taxes , Deferred Compensation , EBITDA , Excise Tax , Income Taxes , Individual Mandate , International Tax Issues , Legislative Agendas , Pass-Through Entities , PFIC , REIT , Section 179 Property , Tax Deductions , Tax Exempt Entities , Tax Rates , Tax Reform , Tax-Exempt Bonds , UBIT

U.S. Senate Passes Its Version of the Tax Cuts and Jobs Act (H.R. 1); Descriptions of the Bills Passed in the House and Senate and...

In the early hours of Saturday morning, the U.S. Senate passed the Tax Cuts and Jobs Act (H.R. 1) (the “Senate bill”), just over two weeks after the U.S. House of Representatives passed its own version of the same legislation...more

12/12/2017  /  401k , 501(c)(3) , 501(c)(6) , Affordable Care Act , Alternative Minimum Tax , Base Erosion Tax , C-Corporation , Controlled Foreign Corporations , Corporate Taxes , Deferred Compensation , EBITDA , Excise Tax , Income Taxes , Individual Mandate , International Tax Issues , Legislative Agendas , Pass-Through Entities , PFIC , Popular , Proposed Legislation , REIT , Section 1031 Exchange , Section 179 Property , Tax Deductions , Tax Exempt Entities , Tax Rates , Tax Reform , Tax-Exempt Bonds , UBIT

House of Representatives Passes the Tax Cuts and Jobs Act (H.R. 1); Senate Finance Committee Approves Modified Version; Comparison...

Yesterday afternoon, the House of Representatives passed the Tax Cuts and Jobs Act (H.R. 1) (the “House bill”). The House bill is identical to the draft bill approved by the House Ways and Means Committee on November 10. Late...more

11/20/2017  /  401k , Adjusted Gross Income , Affordable Care Act , Alternative Minimum Tax , Charitable Deductions , Controlled Foreign Corporations , Corporate Taxes , Deferred Compensation , EBITDA , Employee Benefits , Excise Tax , Foreign Earned Income , Foreign Subsidiaries , Independent Contractors , Individual Mandate , IRS , New Legislation , Pass-Through Entities , Personal Property Tax , PFIC , Popular , REIT , S-Corporation , Section 179 Property , Senate Finance Committee , Shared Responsibility Rule , Tax Deductions , Tax Exempt Entities , Tax Rates

The Senate Finance Committee’s proposal for tax reform, and how it compares with the bill passed by the House Committee on Ways &...

UPDATE: The Senate Finance Committee last night released a revised version of the Chairman’s Mark of the Tax Cuts and Jobs Act. We are reviewing these changes and will release an update soon... On Thursday, November 9, the...more

11/15/2017  /  401k , 403(b) Plans , 457(b) Plans , 501(c)(6) , Alternative Minimum Tax , Capital Gains , CFC , Charitable Deductions , Child Tax Credit , Corporate Taxes , Cost Recovery , DBCF Tax , Deferred Compensation , Domestic International Sales Corporation , EBITDA , Employee Benefits , FDIC , Foreign Corporations , GAAP , Generation-Skipping Transfer , Highly Compensated Employees , Independent Contractors , Mortgage Interest , Partnerships , Pass-Through Entities , PFIC , Section 179 Property , Section 199 , Section 482 , Section 956 , Senate Finance Committee , Social Security Benefits , Sports , Tax Exempt Entities , Tax Exemptions , Tax Rates , Tax Reform , UBTI , Ways and Means Committee

The Tax Cuts and Jobs Act

Today, the Republicans in the U.S. House of Representatives released their long-anticipated tax reform bill, entitled the “Tax Cuts and Jobs Act”. While there have been multiple statements from the Republican majority in the...more

11/3/2017  /  501(c)(3) , Alternative Minimum Tax , Charitable Deductions , Child Tax Credit , Corporate Taxes , Deduction Limitations , EBITDA , Educational Institutions , Estate Tax , FDAP , Foreign Corporations , Foreign Subsidiaries , Fringe Benefits , International Tax Issues , Like Kind Exchanges , Meal and Entertainment Expenditures , Medical Expenses , Multinationals , Net Operating Losses , Parent Corporation , Pass-Through Entities , PFIC , Private Foundations , Property Tax , Proposed Legislation , Religious Institutions , Retirement Plan , Roth IRA , Section 179 Property , Section 409A , Section 457A , Section 501 , Shareholders , Tax Cuts , Tax Exempt Entities , Tax Rates , Tax Reform , Tax-Exempt Bonds

Final Regulations Released Regarding PFIC Ownership Determination and Annual Reporting Requirements

On December 27, 2016, the Treasury Department (Treasury) and Internal Revenue Service (IRS) released final regulations regarding the determination of ownership of a passive foreign investment company ("PFIC") and regarding...more

1/20/2017  /  Business Ownership , C-Corporation , Final Rules , Foreign Corporations , IRS , Passive Foreign Investment Company , PFIC , Reporting Requirements , S-Corporation , Stocks , U.S. Treasury
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JD Supra's principal place of business is in the United States. By subscribing to our website, you expressly consent to your information being processed in the United States.

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Privacy Officer
JD Supra, LLC
10 Liberty Ship Way, Suite 300
Sausalito, California 94965

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Privacy Officer
JD Supra, LLC
10 Liberty Ship Way, Suite 300
Sausalito, California 94965

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