The Internal Revenue Service (IRS) on July 31, 2020, published proposed regulations (Proposed Regulations) on the tax treatment of certain partnership interests held in connection with the performance of services (such...more
A U.S. shareholder of a foreign corporation generally is not subject to U.S. federal income tax on the income of the foreign corporation until the shareholder receives an actual distribution from the corporation. However,...more
The Internal Revenue Service (IRS) has provided taxpayers with needed relief by delaying the due dates with respect to various filings and payments during the coronavirus (COVID-19) pandemic. This relief has been announced in...more
As a result of the coronavirus (COVID-19) pandemic, several legislative and regulatory measures have been promulgated in an effort to assist businesses during the economic downturn. Below is a summary of the most important...more
• The Internal Revenue Service has issued a proposed regulation that in many cases should eliminate the detrimental U.S. tax consequences to a U.S. corporation under Section 956 of the Internal Revenue Code when the...more
11/9/2018
/ Controlled Foreign Corporations ,
Corporate Financing ,
Dividends ,
IRS ,
Limited Liability Company (LLC) ,
Partnerships ,
Proposed Regulation ,
Section 956 ,
Shareholders ,
Subsidiaries ,
Tax Cuts and Jobs Act
President Donald Trump signed the U.S. tax reform bill previously entitled the Tax Cuts and Jobs Act into law on December 22, 2017, enacting comprehensive U.S. tax reform with most provisions becoming effective starting on...more
1/3/2018
/ Base Erosion Tax ,
Capital Gains ,
Carried Interest ,
Corporate Taxes ,
Dividends ,
EBITDA ,
Estate Tax ,
Foreign Corporations ,
Foreign Subsidiaries ,
Foreign Taxpayers ,
Income Taxes ,
International Tax Issues ,
IRS ,
Net Operating Losses ,
New Legislation ,
Pass-Through Entities ,
Royalties ,
Shareholders ,
Small Business ,
Subsidiaries ,
Tax Cuts and Jobs Act ,
Tax Deductions ,
Tax Rates ,
Tax Reform ,
Trump Administration ,
Withholding Tax
Congress released the "Tax Cuts and Jobs Act" on late Friday evening, Dec. 15, 2017. This version of the bill is the result of a conference committee process to marry the different bills previously passed by the U.S. House of...more
12/20/2017
/ Alternative Minimum Tax ,
Business Taxes ,
Capital Gains ,
Carried Interest ,
Corporate Taxes ,
Depreciation ,
Dividends ,
Estate Tax ,
Foreign Subsidiaries ,
Gift Tax ,
GST ,
Income Taxes ,
IRS ,
Itemized Deductions ,
Net Operating Losses ,
Pass-Through Entities ,
Personal Exemptions ,
Proposed Legislation ,
Section 199 ,
Shareholders ,
Standard Deduction ,
Subpart F ,
Tax Code ,
Tax Credits ,
Tax Rates ,
Tax Reform ,
Trump Administration ,
U.S. Treasury
The Bipartisan Budget Act of 2015 (P.L. 114-74) includes a complete overhaul of the procedures that apply to Internal Revenue Service (IRS) audits of partnerships, including limited liability companies (LLCs) taxed as...more
HIGHLIGHTS -
- The IRS has issued a Notice detailing temporary modifications to its enforcement rules having to do with the Foreign Account Tax Compliance Act.
- Under IRS Notice 2014-33, 2014 and 2015 will be...more