News & Analysis as of

Corporate Taxes Tax Planning Trump Administration

Kramer Levin Naftalis & Frankel LLP

New Section 162(m) Proposed Regulations

The Tax Cuts and Jobs Act of 2017 (TCJA) made significant changes to Section 162(m) of the Internal Revenue Code (Section 162(m)), expanding the scope of individuals and entities subject to Section 162(m), in addition to...more

Lowndes

Treasury Strips Away Obama Administration Earnings Stripping Rules

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In 2016, the Obama administration issued a series of rules and regulations designed to stem the flow of corporate inversions – transactions where U.S. corporations moved offshore to avoid the high 35% U.S. corporate tax rate....more

Hogan Lovells

IRS issues initial guidance on application of Code Section 162(m) as amended by the Tax Cuts and Jobs Act

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On August 21, the Internal Revenue Service (IRS) issued Notice 2018-68 containing much-awaited interpretive guidance on Section 162(m) of the Internal Revenue Code as amended by last year's tax reform act (Tax Act), including...more

Pullman & Comley, LLC

Are Connecticut Income Taxes Now Tax Deductible For The Owners Of Pass-Through Entities?

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June 5, 2018 The Tax Cuts and Jobs Act, which was passed by Congress last year, imposed a $10,000 limit on state and local tax (“SALT”) deductions. ...more

Foodman CPAs & Advisors

Make your connection with the “Top 10” Tax Cut and Jobs Act Changes and be prepared for 2019!

Here are the changes from the Tax Cut and Jobs Act (TCJA) that will impact “most” Individuals when they prepare their 2018 Tax Returns in 2019...more

Troutman Pepper

Focus on New Tax Law: Section 199A Pass-Through Deduction and Restrictions on Interest Deductions Tax Update, Volume 2018, Issue 2

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The Tax Cuts and Jobs Act (2017 Tax Act) significantly modified the treatment of certain deductions for many business taxpayers, including partners and partnerships....more

Carlton Fields

New Tax Law Eliminates 30-Day Safe Harbor Against CFC Status

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The recent tax law changes have focused primarily on corporate income tax, and in the international context, mostly on outbound tax matters. However, certain less publicized changes to the Code’s controlled foreign...more

Kramer Levin Naftalis & Frankel LLP

Tax Reform Act Changes to CFC Attribution Rules

The recently enacted tax reform act (the Act) significantly altered the U.S. taxation of foreign income. Perhaps most prominently, the Act allows U.S. corporations to fully deduct (and thus not pay tax on) dividends received...more

Troutman Pepper

How Will Recent Tax Legislation Affect the Renewable Energy Sector?

Troutman Pepper on

The Bipartisan Budget Act of 2018 (Pub. L. No. 115-123) (the Budget Act) was signed into law on February 9. The legislation took effect roughly seven weeks after President Trump signed into law an Act to Provide for...more

Snell & Wilmer

New Tax Act: 2017 Trap for 10% U.S. Owners of Foreign Corporations

Snell & Wilmer on

The Tax Cuts and Jobs Act of 2017 (the “Tax Act”) modifies Section 965 of the Internal Revenue Code (“IRC”) by expanding the definition of “subpart F income” of United States shareholders (“U.S. shareholder”) for the last tax...more

Orrick, Herrington & Sutcliffe LLP

U.S. Tax Reform Has A Profound Impact On Inbound Investment

The current focus of the international tax community is on the United States, and for good reason. In the midst of a contentious political landscape, months of anticipation, and a decidedly clandestine drafting process, U.S....more

Lowndes

Tax Cut and Jobs Act Limits Benefit of Carried Interest

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After many years of being the target of Congress and the IRS, the Tax Cut and Jobs Act finally succeeded in limiting the beneficial tax treatment of carried interests, at least for some taxpayers. This change will be of...more

Pullman & Comley, LLC

ALERT: The Tax Cuts and Jobs Acts Provisions Apply to Colleges and Universities

Pullman & Comley, LLC on

Although much of the reporting on the Tax Cut and Jobs Act recently enacted by Congress has focused on the deductions for individuals and businesses, the bill also includes several provisions that apply specifically to...more

Ruder Ware

More Planning Tips for Individuals Under New Tax Act

Ruder Ware on

As Shanna Yonke mentioned in her January 22, 2018 Legal Update The New Tax Law Provides Estate Planning Opportunities, President Trump signed the Tax Cuts and Jobs Act into law on December 22, 2017. The Act (officially,...more

Foodman CPAs & Advisors

¿Sabía usted que la "Ley" tiene una Deducción por Dividendos Recibidos (DRD)?

La "Ley de Reducción de impuestos y empleos" (la "Ley") tiene el propósito declarado de que los EE.UU. se convierta a un sistema de impuestos “territorial". Antes de que se aprobara la Ley, la mayoría de las empresas de los...more

Pullman & Comley, LLC

Tax Cuts and Jobs Act

Pullman & Comley, LLC on

Although much of the reporting on the Tax Cut and Jobs Act recently enacted by Congress has focused on the deductions for individuals and businesses, the bill also includes several provisions that apply specifically to...more

Foodman CPAs & Advisors

Did you know that the “Act” has a Deduction for Dividends Received (DRD)?

The “Tax Cuts and Jobs Act” (the “Act”) has a stated purpose of converting the U.S. to a “territorial” tax system. Before the Act was approved, most U.S. companies were incentivized to keep their earnings offshore. In the...more

Foodman CPAs & Advisors

Accionistas Estadounidenses que poseen el 10% o más tienen un mandatorio nuevo “impuesto de transición”

La "Ley de reducción de impuestos y empleos" (la "Ley") tiene una provisión que requiere que los Contribuyentes Estadounidenses que poseen el 10% o más de una Corporación Controlada Extranjera (Controlled Foreign...more

Troutman Pepper

Effective NOL Planning in Light of Tax Reform

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Can your company unlock the value of net operating loss carryforwards to reduce future taxable income? Originally published in Tax Executive, the professional journal of Tax Executives Institute - January/February 2018....more

Foodman CPAs & Advisors

U.S. 10% Shareholder Taxpayers have a new Mandatory “Transition Tax”

The “Tax Cuts and Jobs Act” (the “Act") has a provision requiring U.S. Shareholder Taxpayers that own 10% or more of a Controlled Foreign Corporation (CFC) and other “Specified Foreign Corporations” to pay a “transition tax”....more

Orrick, Herrington & Sutcliffe LLP

Private Equity Fund Taxation Post-Tax Reform: What Really Changed?

Congress has passed the tax reform bill, known as the “Tax Cuts and Jobs Act” (the “Act”), and President Trump signed it into law on December 22, 2017. The Act contains wide-ranging changes to the tax law, many of which will...more

Bradley Arant Boult Cummings LLP

Viewpoint: Alabamians get another reason to fund tax-credit scholarships

With the Dec. 22 enactment of the federal Tax Cuts and Jobs Act, many Alabamians and companies doing business in our state should see a reduction in their 2018 federal income tax bills but, somewhat surprisingly, an increase...more

Lowndes

Six Things to Know About the New Interest Expense Limitation

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Last month, President Trump signed into law the much publicized Tax Cut and Jobs Act. In part of our ongoing series discussing the changes made by the Act, the following answers six common questions regarding the new Section...more

Gray Reed

New Tax Law – Impacting Your Small Business and You

Gray Reed on

Agreeing with Benjamin Franklin that there is nothing certain except death and taxes, Sketch Wood and his partner Minnie Brix, owners of Wood & Brix, and their 200 employees are certain that the new tax law will affect them,...more

Lowndes

How the Tax Cut and Jobs Act Impacts Expensing and Depreciation (For the Better)

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Last month, President Trump signed into law the much publicized Tax Cut and Jobs Act. In part of our ongoing series discussing the changes made by the Act, the following discusses key changes made to the expensing and...more

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