News & Analysis as of

Corporate Taxes Tax Cuts and Jobs Act Federal Taxes

Miller Canfield

Can Legislative History Restore a Repealed IRC Provision?

Miller Canfield on

Altria Group, Inc. v. United States, a federal income tax case pending in federal district court in Virginia, shows the importance of laying groundwork for litigation long before a complaint is filed. At issue is a difficult...more

Brownstein Hyatt Farber Schreck

A Look Ahead into Tax Policy in 2024

As Congress heads into 2024 and President Biden starts the last year of his term, a host of tax issues remain unaddressed, including a much-anticipated expiring tax provisions package, pending regulatory guidance, the outcome...more

McDermott Will & Emery

Weekly IRS Roundup December 16 – 20, 2019

McDermott Will & Emery on

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of December 16 – 20, 2019. December 16, 2019: The IRS released a notice extending the phase-in...more

King & Spalding

Renewed Interest in Synthetic Leases - A Refresher and Changes Under the New (ASC 842) Lease Accounting Standard

King & Spalding on

A synthetic lease is a financing technique structured to be an operating lease for the lessee’s financial accounting purposes and a financing for U.S. federal tax purposes. Synthetic leases are most often used in acquisition...more

Bradley Arant Boult Cummings LLP

Alabama Legislature Passes Landmark Financial Institution Excise Tax Reform Bill and Forms Corporate Tax Reform Study Group - SALT...

On Tuesday night, May 28, Gov. Kay Ivey signed into law House Bill 419, the Alabama Financial Institution Excise Tax Reform Act of 2019 (FIETRA), which resulted from a collaborative effort between the banking community,...more

Bilzin Sumberg

Looking for a GILTI-Free Structure? Try Estonia

Bilzin Sumberg on

Estonia, the small Baltic country of just 1.3 million people situated halfway between Sweden and Russia, was named “the most advanced digital society in the world” by Wired magazine. According to recent figures, Estonian...more

Fenwick & West LLP

The New Foreign Tax Credit Proposed Regulations – An Executive Summary

Fenwick & West LLP on

Released on November 30, 2018, the foreign tax credit proposed regulations provide a comprehensive new framework for calculating the foreign tax credit in light of several changes made by the Tax Cuts and Jobs Act (TCJA or...more

Alston & Bird

State of Uncertainty: GILTI Considerations for Individuals

Alston & Bird on

Our International Tax Group explores the hidden terrain for individuals found in the new tax on global intangible low-taxed income (GILTI). - The Section 250 deduction - The renewed importance of Section 962 - Beware of...more

Fenwick & West LLP

Impact of Tax Reform on the Purchase and Sale of Controlled Foreign Corporations — Selected Considerations

Fenwick & West LLP on

The application of §1248 and §338(g) in the context of the purchase or sale of a controlled foreign corporation (CFC) has long been one of the most complex areas of the tax code. The recently enacted tax reform act — herein,...more

Bradley Arant Boult Cummings LLP

COST Weighs-In on Alabama DOR’s Analysis of Federal Tax Reform - SALT Alert: Alabama Edition

On July 31, the Alabama Department of Revenue (ADOR or Department) released its long-awaited and quite comprehensive analysis of the impact of the Tax Cuts and Jobs Act of 2017 (otherwise known as “federal tax reform”) on...more

Skadden, Arps, Slate, Meagher & Flom LLP

New York State Responds to Federal Tax Reform

On March 30, 2018, the New York Legislature passed the 2018–2019 Budget Bill (SB. 7509-C/A 9509-C) (Budget Bill), which addresses several provisions of the newly enacted Tax Cuts and Jobs Act (P.L. 115-97) (TCJA) and...more

Sullivan & Worcester

Impact of 2017 Tax Act on Real Estate Activities

Sullivan & Worcester on

The first, global observation to share is that the real estate industry dodged a lot of potential bullets during the tax reform process and came out smelling like roses – indeed, actually came out ahead, overall, under the...more

Allen Matkins

4 Ways the Federal Tax Overhaul Affects Commercial Real Estate

Allen Matkins on

The 2017 “Tax Cuts and Jobs Act” is the most significant change to U.S. tax law in 30 years. It lowered the maximum federal corporate tax rate from 35 percent to 21 percent, as well as lowering rates for many individuals,...more

Perkins Coie

New Three-Year Hold Requirement for Carried Interests

Perkins Coie on

The 2017 Tax Cuts and Jobs Act (the Act), signed by President Trump last month, significantly affects the ability of the managers of investment funds to receive long-term capital gains with respect to their carried interest....more

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