Welcome to May's edition of the UK Tax Round Up. This month has seen a number of interesting court decisions, an important opinion of the European Commission’s Advocate General and the commencement of a Treasury consultation...more
In Haworth v HMRC the Supreme Court (SC) upheld the Court of Appeal’s (CA’s) decision to quash a follower notice (FN) and accelerated payment notice (APN) issued to the taxpayer, Mr Haworth. An FN can be issued by HMRC where...more
Proposed Regulations under Section 4960 of the Internal Revenue Code provide important guidance for tax-exempt organizations and their affiliates regarding an excise tax on certain executive compensation. The U.S. Department...more
UK General Tax Developments - Date set for next UK Budget - The first Budget of the new Conservative government will be held on Wednesday 11 March. There has been significant speculation that there will be a major...more
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
Even during the recent government shut down, the Internal Revenue Service issued guidance on the “excess parachute” provisions applicable to tax-exempt organizations under the 2017 Tax Cuts and Jobs Act (the “Act”). IRS...more
In Notice 2019-09 (“Notice”), the IRS provides relief from the new excise tax to certain colleges and universities that pay their “covered employees” more than $1 million per year or pay excess parachute payments....more
Just in time for the New Year and notwithstanding the government shutdown, on December 31, 2018, the Internal Revenue Service (“IRS”) issued Notice 2019-09 (the “Notice”), which provides interim guidance on the new excise tax...more
The IRS issued Notice 2019-09, which provides interim guidance in a fairly lengthy Q&A format relating to Code Section 4960, enacted on December 22, 2017....more
As is well known, on December 22, 2017, President Trump signed the Tax Cuts and Jobs Act (the “Final Bill”) into law. During the course of this massive legislative effort, various provisions affecting tax-exempt organizations...more
The Administration’s frenzy to pass “tax reform” created tax breaks for some—I’m looking at you, the Trump family—increased taxes for others, and confusion for everyone, at least until the IRS is able to promulgate official...more
The Tax Act contains a number of provisions that significantly affect tax-exempt organizations, in some cases to degrees not seen in decades. In addition, several provisions may indirectly affect tax-exempts, for example, by...more
The Tax Cuts and Jobs Act, signed into law by President Donald J. Trump shortly before Christmas, is the most significant tax reform legislation in more than 30 years. ...more
On Friday, December 22, 2017, President Trump signed into law the Tax Cuts and Jobs Act (the Act). While the emphasis of the Act focused on the reduction of corporate rates, and the repeal of the Affordable Care Act's...more
The 2017 “Tax Cuts and Jobs Act” impacts tax-exempt organizations in a variety of ways, including by reducing incentives for charitable giving, applying an excise tax on executive compensation in excess of $1 million per...more
The Tax Cuts and Jobs Act, which has been renamed the Amendment of 1986 Code, was signed into law by President Trump on December 22, 2017. Many are calling it the most sweeping overhaul to the United States tax system in...more
On Friday, December 15, 2017, Congress put forth a final version of the Tax Cuts and Jobs Act, which would signify the largest piece of tax legislation in over thirty years if signed into law. Early in the morning on December...more
On December 20, 2017, Congress passed the Tax Cuts & Jobs Act (TCJA), which now awaits President Trump’s signature. Among many changes that the TCJA will bring to current federal tax law, several will affect tax-exempt,...more
UK Tax News and Developments - The OTS publishes its report "Value added tax: routes to simplification" - On 7 November, the Office of Tax Simplification (OTS) published its first report on VAT, which included a range...more
On November 20, 2017, the Senate Finance Committee released legislative text of its version of the Tax Cuts and Jobs Act, which contains proposals modifying certain executive compensation provisions of the Internal Revenue...more
UK Tax News and Developments - Finance (No 2) Bill 2017 - The second Finance Bill of 2017, known as Finance (No 2) Bill 2017, has now been published. As expected, this contains most of the provisions which were dropped from...more