New anti-abuse provisions
The Biden-Harris administration announced its American Jobs Plan, a legislative framework laying out an ambitious $2 trillion investment in physical and human infrastructure, on March 31. The bulk of the proposed spending is...more
On November 4, 2019, the Internal Revenue Service (IRS) announced a new Large Business and International (LB&I) compliance campaign regarding Section’s 965 transition tax under the Tax Cuts and Jobs Act (TCJA). This is one of...more
On December 20, 2018, the Internal Revenue Service (the “IRS”) and the Department of the Treasury (the “Treasury”) released proposed “anti-hybrid” regulations (the “Proposed Regulations”) under sections 267A, 245A(e), and...more
Section 199A, enacted in the Tax Cuts and Jobs Act at the end of 2017, allows individuals and certain noncorporate taxpayers to deduct up to 20 percent of qualified business income (QBI) beginning in 2018. QBI generally...more
Recent tax legislation, informally known as the Tax Cuts and Jobs Act (the “Act”) contains several changes that affect the insurance industry....more
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
On December 22, 2017, President Trump signed broad tax reform legislation into law that, among other things, reduced the corporate income tax rate to 21 percent and reformed the US international tax system. This article...more
The newly passed tax legislation significantly alters the landscape for international business. The final Republican tax cut bill moves the U.S. from a so-called "global taxation regime" to a territorial taxation regime in...more
On December 20, 2017, both the House and the Senate passed H.R. 1 (the “Bill”), which President Trump is expected to sign by January 3, 2018. The Bill dramatically alters the U.S. approach to domestic and international...more
The tax bill passed by Congress on December 20, 2017, contains many improvements for renewable energy from the original House draft of the tax reform bill, including retaining existing credits and reducing the impact of the...more
On December 2, 2017, the Senate approved its version of the Tax Cuts and Jobs Act. The Senate Bill includes the base erosion and anti-abuse tax, a new tax intended to apply to companies that significantly reduce their US tax...more