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
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
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
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
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
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