News & Analysis as of

Taxable Income Tax Cuts and Jobs Act

Rivkin Radler LLP

Taxing A Foreigner’s Sale of a Partnership Interest – Déjà Vu All Over Again

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There is no denying that many parts of the Code are complex and, in some cases, too obscure for many “laypersons” to comprehend. Over time, this reality spawned the need for advisers who are both knowledgeable and experienced...more

McDermott Will & Emery

Finalization of Foreign Tax Credit Rules on Disregarded Payments (Effective Retroactively)

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On January 4, 2022, the U.S. Department of the Treasury and the Internal Revenue Service (IRS) published its third set of final regulations on foreign tax credits (the “Final Regulations”) since the enactment of the Tax Cuts...more

Rivkin Radler LLP

The Biden Administration’s Revenue Proposals For Fiscal Year 2022: Tax Increases And Forced Recognition Of Capital Gains

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Extra, Extra!- Last Friday afternoon, as millions of unsuspecting Americans prepared for the long Memorial Day weekend – for many, perhaps, their first mask-less holiday celebration in almost 15 months – the Biden...more

Eversheds Sutherland (US) LLP

Rev. Proc. 2021-26 provides accounting method change procedures for CFCs seeking to use the alternative depreciation system

Recently released Revenue Procedure 2021-26 (the Revenue Procedure) provides taxpayers with guidance regarding accounting method changes made on behalf of foreign corporations. The Revenue Procedure: ..Allows controlled...more

Rivkin Radler LLP

The President’s Recent Tax Proposals: What Do They Mean For Business Owners?

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A Night to Remember? Did you listen to the President’s speech last Wednesday? He addressed a joint session of Congress to pitch the Administration’s $1.8 trillion American Families Plan. Due to COVID-related...more

Rivkin Radler LLP

New York Is Getting Out Of The Zone, The Qualified Opportunity Zone, That Is

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New York’s Governor Cuomo is having a bad 2021. Some may attribute this to his hubris or to karma; others may point to an emboldened, and now veto-proof, progressive State Legislature; many will claim that Mr. Cuomo is paying...more

Rivkin Radler LLP

New York Budget Deal Includes SALT Cap Workaround

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The New York state budget deal announced yesterday includes a workaround of the temporary federal limit on state and local tax deductions (the SALT cap). The provision was part of Gov. Cuomo’s initial budget proposal in...more

McDermott Will & Emery

New Final Regulations Revise Rules on the Application of Section 163(j) to CFCs

McDermott Will & Emery on

As amended by the Tax Cuts and Jobs Act (TCJA), section 163(j) of the Internal Revenue Code (the Code) provides that a taxpayer’s interest expense is deductible only to the extent of the sum of: (i) the taxpayer’s interest...more

Farrell Fritz, P.C.

New York’s Proposed “Billionaires’ Tax” – Bad Idea

Farrell Fritz, P.C. on

Will They Leave? Over the years, the Democrats in Albany have regularly made noise about increasing the rates at which New York State taxes the income of its wealthier residents. With the election of Governor Cuomo in...more

Farrell Fritz, P.C.

NYC Real Estate: Post-Virus Tax Planning Can Help

Farrell Fritz, P.C. on

NYC Real Estate on the Ropes- In March of this year, the Department of Homeland Security classified real estate as an “essential business.” I imagine that the person in Washington who suggested that real estate be added to...more

McDermott Will & Emery

New Proposed Regulations Would Revise the Application of Section 163(j) to CFCs

McDermott Will & Emery on

As amended by the Tax Cuts and Jobs Act (TCJA), section 163(j) of the Internal Revenue Code (the Code) provides that a taxpayer’s interest expense is deductible only to the extent of the sum of: (i) the taxpayer’s interest...more

Eversheds Sutherland (US) LLP

The newest addition to your summer reading list: Section 163(j) regulations arrive just in time for the dog days of summer

On July 28, 2020, the Internal Revenue Service (IRS) and Department of the Treasury (Treasury) issued final and newly-proposed regulations under section 163(j) that taxpayers and practitioners alike were eagerly awaiting....more

Chambliss, Bahner & Stophel, P.C.

How Changes to Claiming Net Operating Losses Under the CARES Act Impact Businesses

Under the CARES Act, taxpayers with 2018, 2019, and 2020 net operating losses (“NOLs”) may now be able to obtain tax relief by filing amended returns to claim tax refunds by offsetting taxable income from prior years. The...more

Obermayer Rebmann Maxwell & Hippel LLP

Economic Development Grants – Good News, Bad News

Your application to receive a state or municipal economic development grant for your real-estate development project has been approved. That’s good news! The bad news is that the grant might be taxable income, thanks to the...more

McDermott Will & Emery

IRS Proposes Section 163(j) Regulations – New Business Interest Expenses Deduction Limit

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On November 26, 2018, the Internal Revenue Service (IRS) issued proposed regulations (Proposed Regulations) pursuant to section 163(j). Public Law 115-97, the Tax Cuts and Jobs Act (TCJA), amended Internal Revenue Code (Code)...more

Eversheds Sutherland (US) LLP

New York bill introduced to exempt GILTI

On June 11, 2018, Senate Bill 8991 (the Bill) was introduced by New York Senate Majority Leader John Flanagan. The Bill would decouple from the federal treatment of Global Intangible Low-Taxed Income (GILTI). ...more

Bradley Arant Boult Cummings LLP

New Limitations on Deductions for Interest Payments May Impact Many Family Businesses

The new Tax Cuts and Jobs Act limits the ability of many businesses to deduct interest payments. Under prior law, any interest expense was generally deductible. Now, many businesses are prohibited from deducting any interest...more

Foster Garvey PC

Decoding the Tax Cuts and Jobs Act – Part V: Changes to IRC §163(j) and the Business Interest Deduction Rules

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“Neither a borrower nor a lender be...” or at least, if you insist on borrowing (and we understand the appeal), we are here to help you stay abreast of the new rules on deducting interest. BACKGROUND/PRIOR LAW - Interest...more

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