Welcome to this week’s edition of Tax Bytes. Our team of tax lawyers is actively monitoring for federal and international tax developments and issues of note. Each week we pull together the items we deem most important to...more
6/12/2025
/ Base Erosion and Anti-Abuse Tax (BEAT) ,
Cryptoassets ,
Financial Institutions ,
Financial Services Industry ,
Foreign Derived Intangible Income (FDII) ,
GILTI tax ,
IRS ,
OECD ,
Reporting Requirements ,
Tax Credits ,
Tax Cuts and Jobs Act
In mid-January, the House introduced the Tax Relief for American Families and Workers Act (Act). The Joint Committee of Taxation has released its explanation of the Act, and the House Ways and means Committee has released a...more
1/31/2024
/ Affordable Housing ,
Congressional Committees ,
Filing Requirements ,
FIRPTA ,
Foreign Corporations ,
Low Income Housing ,
Mortgage REITS ,
Proposed Legislation ,
Relief Measures ,
Taiwan ,
Tax Credits ,
Tax Cuts and Jobs Act ,
Tax Extenders ,
Tax Treaty
On June 27, US Senators Joe Manchin and Chuck Schumer announced proposed legislation referred to as the Inflation Reduction Act of 2022 (the Act). The proposed legislation includes changes that would expand the scope of IRC...more
8/2/2022
/ C-Corporation ,
Carried Interest ,
Holding Periods ,
Internal Revenue Code (IRC) ,
Investors ,
IRS ,
Partnership Interests ,
Partnerships ,
Pass-Through Entities ,
Proposed Regulation ,
Tax Cuts and Jobs Act
On July 28, 2020, Treasury and the IRS released highly anticipated final regulations under section 163(j) and related amended regulations under sections 382 and 383 (Final Regulations). This legal alert focuses on provisions...more
The Tax Cuts and Jobs Acts (TCJA) repealed § 958(b)(4) of the Code, which prevented downward attribution of stock ownership from a foreign person to a US person. That repeal has resulted in many foreign corporations being...more
10/14/2019
/ Controlled Foreign Corporations ,
Corporate Taxes ,
Domestic Corporations ,
Foreign Entities ,
GILTI tax ,
Internal Revenue Code (IRC) ,
IRS ,
Proposed Regulation ,
Repeal ,
Reporting Requirements ,
Revenue Procedures ,
Safe Harbors ,
Tax Cuts and Jobs Act ,
U.S. Treasury
On September 5, 2019, the Internal Revenue Service (Service) and the Department of Treasury (Treasury) issued proposed regulations for Section 451(c) of the Internal Revenue Code (Code). Section 451(c) was added to the Code...more
Public Law 115-97 (the Tax Cuts and Jobs Act (TCJA)) added a new foreign income inclusion rule for global intangible low-taxed income (GILTI) under section 951A. On September 13, 2018, the Department of the Treasury...more
9/25/2018
/ Controlled Foreign Corporations ,
Corporate Taxes ,
Foreign Tax Credits ,
GILTI tax ,
Income Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
Partnerships ,
Proposed Regulation ,
Shareholders ,
Tax Cuts and Jobs Act ,
U.S. Treasury
On August 1, 2018, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued proposed regulations, which were published in the Federal Register on August 9, 2018 (Proposed Regulations),...more