Podcast: Illinois Tool Works Inc. & Subsidiaries v. Commissioner of Internal Revenue
Is it possible for the IRS to leave more in our paychecks in 2024? What has changed for the 2024 federal income tax brackets and how will these apply to the tax return(s) you’ll file in 2025?...more
Consider the estate tax planning implications before relocating - Suppose you’re contemplating a bold move — literally: pulling up stakes and moving to a foreign country. There are many possible reasons for this drastic...more
The final and proposed regulations under sections 951A and 954 of the US Internal Revenue Code contain certain rules that may present planning opportunities—or possibly onerous results—depending on a taxpayer’s specific fact...more
On October 16, 2018, the Organization for Economic Cooperation and Development (OECD) issued guidance to Financial Institutions (FIs) regarding what is known as “Golden Passports”. ...more
Introduction - U.S. taxation of intellectual property has become astoundingly more complex after the Tax Cuts and Jobs Act. The new rules are so complex that the IRS and Treasury are still figuring out the details of how...more
Pro “C” Corporation Bias? Although closely-held businesses have generally welcomed the TCJA’s amendments to the Code relating to the taxation of business income, many are also frustrated by the complexity of some of these...more
The Treasury Department and the Internal Revenue Service (IRS) issued Notice 2018-26, which provides guidance under section 965 of the Internal Revenue Code regarding the “transition tax.” Section 965 imposes a transition tax...more
We’ve all heard about the profits that publicly-held U.S. corporations have generated overseas, and how those profits have, until now, escaped U.S. income taxation by virtue of not having been repatriated to the U.S. It...more
Signed into law December 22, 2017, the "Tax Cuts and Jobs Act" represents the most comprehensive reform to the U.S. federal tax code in a generation. The Act's most notable provisions include significant reductions in both...more
On December 15, the House and Senate Conference Committee released the conference report on the Tax Cuts and Jobs Act (the “Conference Committee Report” or “Report”), containing the specific details on the tax plan they hope...more
On Nov. 16, 2017, the House passed its tax reform bill, the Tax Cuts and Jobs Act (“House Bill”). The bill materially changes taxation of pass-through income from partnerships, LLCs taxed as partnerships and S corporations....more
Yesterday afternoon, the House of Representatives passed the Tax Cuts and Jobs Act (H.R. 1) (the “House bill”). The House bill is identical to the draft bill approved by the House Ways and Means Committee on November 10. Late...more
On November 16, the House passed the Tax Cuts and Jobs Act (the “House Bill”) by a 227-205 vote. Also on November 16, members of the Senate Finance Committee voted 14-12 to approve their own tax bill (the “Senate Plan”). The...more
On November 9, 2017, the Joint Committee on Taxation (the "JCT") released a summary of the Senate's proposal (in the form of a description of the Chairman's Mark of the "Tax Cuts and Jobs Act," referred to in this alert as...more
With the release yesterday by the House Ways and Means Committee of draft statutory text of the Tax Cuts and Jobs Act (“Chairman’s Mark”), and with GOP majorities in both chambers of Congress proceeding under budget...more
The House Republican’s tax reform bill – the Tax Cuts and Jobs Act – was released today. This bill is 429 pages (this is simplifying?) and provides for extensive tax reform....more
NUMBER OF THE WEEK: 10 percent. Rate of the one-time deemed repatriation tax on U.S. multinationals’ foreign earnings under GOP presidential candidate Donald Trump’s tax plan released Sept. 28. The revenue raised through...more
Although the American Taxpayer Relief Act of 2012 (“Fiscal Cliff Legislation”) passed last week does not contain any sweeping changes targeted at U.S. taxpayers living abroad, a number of provisions are relevant to such U.S....more