Episode 93: Maximiliano Concha Rodríguez | PAGBAM Schwencke, Chile
How Tax Works - Entity Selection
GILTI Conscience Podcast | Spotlight Series: A Celebration of Pride Month With IRS Veteran De Lon Harris
TRAs: Benefits, Complexities (and Private Jets) Explained with Tax Attorney David Peck
GILTI Conscience Podcast | Dissecting Cross-Border Transfer Pricing Resolutions
Exámenes de constitucionalidad a la reforma tributaria ¿en qué vamos?
GILTI Conscience Podcast | Inside the IRS: A Conversation With Former Agency Officials
GILTI Conscience Podcast | Pillar Two Analysis: An Asia Pacific Viewpoint
GILTI Conscience Podcast | Gearing Up for Pillar Two
AGG Talks: Cross-Border Business - Corporate Considerations for Scaling Across Borders
GILTI Conscience Podcast | Spotlight Series: Utilizing Tax Knowledge for the Greater Good
GILTI Conscience Podcast | Spotlight Series: Beyond the Technical Side of Tax Law
10 Things Lawyers Should Know About BVI Transactions
JONES DAY PRESENTS®: The Future of Transfer Pricing in Australia: Implications of the Glencore Decision
The Biden Tax Plan
Tax Planning Under a Biden Presidency
2020 Presidential Candidates' Tax Proposals
New anti-abuse provisions
Podcast: Illinois Tool Works Inc. & Subsidiaries v. Commissioner of Internal Revenue
Impact of environmental, social and governance agenda on tax
On April 10, 2020, the Internal Revenue Service (the “IRS”) issued Revenue Procedure 2020-22 (the “Revenue Procedure”), which (1) permits an “electing real property trade or business” that elected not to be subject to the...more
On August 21, the IRS issued Notice 2018-68 to provide guidance on changes to Internal Revenue Code Section 162(m), enacted by the Tax Cuts and Jobs Act of 2017 (TCJA). Section 162(m) generally limits the tax deduction...more
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
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
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
As we previously reported, following the tax reform package passed in December, private equity limited partner investors based outside the United States are now subject to tax on gains from the sale of partnership interests. ...more
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
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
The recently passed Tax Cuts and Jobs Act eliminated the corporate alternative minimum tax (AMT). Before its repeal, a corporate taxpayer that was subject to the AMT was entitled to indefinitely carry forward the AMT taxes...more
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
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
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
Against all odds, Congress, on a straight party-line vote, enacted the most significant tax reform the U.S. has witnessed in more than 30 years. The tax reform legislation, known as the “Tax Cuts and Jobs Act,” significantly...more
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
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
Two recent developments, generated from the tidal forces of the #MeToo movement should get manufacturers’ attention. On December 22, 2017, Congress adopted a comprehensive tax reform law. Included in the statute is an...more
The Tax Cut and Jobs Act made several important changes to the net operating loss (“NOL”) rules. The following is a brief discussion of these changes. Businesses that generate significant NOLs, such as real estate companies...more
Under the Tax Cuts and Jobs Act, Congress is now offering a new 20% deduction for “pass-through” businesses – i.e. businesses that are not corporations. With the corporate tax rate being reduced under the new law to a flat...more
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
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
One of the more significant changes in the recently enacted Tax Cuts and Jobs Act is new Internal Revenue Code Section 199A, Qualified Business Income. Although touted as providing tax simplification, the Tax Cuts and Jobs...more
The Equipment Leasing and Finance Association has published our article The Impact of Tax Reform: What Leasing Companies Need to Know (subscription required). We are also pleased to be able to make the article available in...more
Included in the recently enacted federal tax reform legislation is the Investing in Opportunity Act (the “Act”) which establishes the Opportunity Zones Program (the “Program”). The Program aims to spur private investment in...more
The Federal Energy Regulatory Commission (FERC) Staff has initiated inquiries involving numerous interstate natural gas pipelines, seeking information on the impact of the Tax Cuts and Jobs Act of 2017 (Tax Act) on those...more