News & Analysis as of

Internal Revenue Code (IRC)

IRS Rules Gift Splitting Differs for Gift and GST Tax Purposes

by Genova Burns LLC on

In PLR 201811002 the IRS has ruled that gift splitting works differently when applied to Gift taxes and Generation Skipping Transfer (GST) taxes. Gift splitting is authorized by IRC Section 2513(a)(1) and states, generally,...more

Ropes & Gray Podcast - Lender Management LLC v. Commissioner of Internal Revenue

by Ropes & Gray LLP on

In this Ropes & Gray podcast, Gabby Hirz, counsel in the tax controversy group, is joined by Loretta Richard, a partner in the tax and benefits group and co-founder of the tax controversy group, and Christi Lazo, counsel in...more

Practical Insights on Tax Reform: Impact on Individuals

On December 22, 2017, President Trump signed into law legislation, known as the Tax Cuts and Jobs Act (“TCJA”), which is the most extensive overhaul of the United States of the Internal Revenue Code (the “Code”) in 30 years....more

New Mexico Administrative Hearings Office Issues Timely Opinion Regarding State Taxation of Subpart F Income and Dividends from...

by McDermott Will & Emery on

Earlier this month, the New Mexico Administrative Hearings Office issued an opinion that addressed the questions on the minds of many state tax professionals in the wake of federal tax reform: under what circumstances can a...more

IRS Issues Withholding Guidance on Transfers of Non-Publicly Traded Partnership Interests by Non-US Persons

by Morgan Lewis on

The Internal Revenue Service announces forthcoming regulations in relation to “ECI withholding” under Section 1446(f). It also announces interim relief and guidance for taxpayers pending regulations....more

IRS Issues FAQs on Paid Family and Medical Leave Tax Credit

by Littler on

The IRS has issued FAQs to provide guidance to employers relating to portions of the newly enacted Tax Cuts and Jobs Act of 2017 that created the Paid Family and Medical Leave Tax Credit....more

Draft North Carolina Tax Legislation Released

by Smith Anderson on

On April 11, 2018, the General Assembly’s Revenue Laws Study Committee released a draft tax bill for possible introduction in the legislative session that convenes May 16. This Alert provides a summary of the more important...more

Fifth Circuit Opinion Vacates DOL Fiduciary Rule

by Dechert LLP on

The U.S. Court of Appeals for the Fifth Circuit on March 15, 2018 issued an opinion (Opinion) vacating the Department of Labor (DOL) fiduciary rule and related applicable exemptions. The DOL had promulgated the rule and...more

Industrial Development Bonds And The Mystery Of Federal Preemption

by Allen Matkins on

This should be a straightforward question - Are qualification and registration requirements under state securities laws preempted with respect to industrial development bonds? When Congress enacted the National Securities...more

Congress Acts to Expose Sexual Harassment — But Protects Itself and Other Surprising HR Consequences of 'Tax Reform'

by Lane Powell PC on

Elsewhere I have written about how the so-called “Tax Cuts and Jobs Act” — enacted this past December under the banner of “Tax Reform” — altered relationships between employers and employees. A closer look at three new...more

Much ado about nothing - IRS provides advance payments guidance with release of Notice 2018-35

On April 12, 2018, the Treasury Department and the Internal Revenue Service (IRS) issued Notice 2018-35 (Notice) that provides transitional guidance relating to advance payments under Rev. Proc. 2004-34. Despite the...more

What’s in Your Health Savings Account?

by Thompson Coburn LLP on

According to an Employee Benefits Research Institute (EBRI) issue brief, approximately 20 million individuals maintained health savings accounts (HSAs) in 2016. Of the 5.5 million HSA accounts represented in EBRI’s HSA...more

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

Global Private Equity Newsletter - Winter/Spring 2018 Edition: Snapshot of Tax Act Changes for PE Funds and their Portfolio...

by Dechert LLP on

President Trump signed into law tax legislation commonly referred to as the Tax Cuts and Jobs Act (the “Tax Act”) on December 22, 2017. The Tax Act implemented the most far-reaching changes to the Internal Revenue Code (the...more

Recent Guidance Regarding Withholding on Certain Transfers of Partnership Interests by Non-U.S. Persons

On April 2, 2018, the U.S. Treasury Department and the Internal Revenue Service (IRS) issued Notice 2018-29, "Guidance Regarding the Implementation of New Section 1446(f) for Partnership Interests That Are Not Publicly...more

IRS issues guidance on dispositions of partnership interests by non-U.S. investors

by Ropes & Gray LLP on

On April 2, 2018, the Internal Revenue Service (“IRS”) issued Notice 2018-29 (the “Notice”), which provides important interim guidance on the new withholding regime created as part of last December’s tax reform legislation,...more

Taxpayers may have to pay Section 965 Transition Tax when filing their 2017 Tax Returns

by Foodman CPAs & Advisors on

Section 965 of the Internal Revenue Code requires certain U.S. Shareholders to pay a transition tax on the untaxed foreign earnings of certain Specified Foreign Corporations as if those earnings had been repatriated to the...more

IRS Releases Notice Addressing the "Transition Tax" Under Section 965 of the Code

On April 2, 2018, the U.S. Treasury Department and the Internal Revenue Service (IRS) released Notice 2018-26 (the Notice), which provides guidance addressing the so-called "transition tax" or "toll charge" described in...more

Party to a suit or agreement with respect to actual or potential violations of law?—Take notice: IRS issues transitional reporting...

On March 27, 2018, the Internal Revenue Service (IRS) issued Notice 2018-23 (the Notice), providing transitional guidance for parties to suits and agreements covered by sections 162(f) and 6050X of the Internal Revenue Code...more

Multinational Financial Groups After the U.S. Tax Reform: Selected Inbound and Outbound Issues

by Latham & Watkins LLP on

Introduction and Overview - The Tax Cuts and Jobs Act (“TCJA”) resulted in the most sweeping changes to the Internal Revenue Code (the “Code”) in decades and will result in countless articles and commentary to address the...more

RMDs: Another Concern for 403(b) Plans

by McNair Law Firm, P.A. on

Section 403(b) of the Internal Revenue Code of 1986, as amended (the “Code”) authorizes a type of retirement plan that can be sponsored by certain tax exempt organizations (e.g., a Code Section 501(c)(3) organization,...more

Deducting Attorneys’ Fees Under the Tax Cuts and Jobs Act of 2017

The Tax Cuts and Jobs Act of 2017 (the “2017 Act”) purports to bring broadly lower tax rates to most U.S. individuals and companies; however, it does so at the expense of clear tax policy objectives in many areas. That lack...more

Georgia Legislature enacts significant income, sales, and property tax legislation

The Georgia legislative session concluded on March 29, 2018. In addition to two major bills relating to federal tax reform, Georgia enacted several other pieces of notable tax legislation....more

Overview of Minnesota’s Response to Federal Tax Reform

by McDermott Will & Emery on

Minnesota has several bills pending that would address the Minnesota state tax implications of various provisions of the federal tax reform legislation (commonly referred to as the Tax Cuts and Jobs Act)....more

Update: Tax Planning Alert - Amounts Paid at Direction of Government or Specified Non-Government Entities - New IRC sec. 162(f)

by Kelley Drye & Warren LLP on

The Internal Revenue Service has issued Notice 2018-23 (dated March 27, 2018) to implement transitional guidance for application of new IRC secs. 162(f) and 6050X. As described in our previous Client Advisory, those new tax...more

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