Possible Tax Filing and Payment Extension. At a House subcommittee meeting yesterday, March 11, 2020, Treasury Secretary Steven Mnuchin announced that the Treasury Department is considering extending the deadline for certain...more
Recently, several of the presidential candidates and other prominent Democrats have suggested a number of different tax policy proposals, including wealth taxes, mark-to-market taxation, a VAT, additional taxes, increased...more
2/28/2020
/ Capital Gains Tax ,
Corporate Taxes ,
Estate Tax ,
Executive Compensation ,
Financial Transaction Tax ,
GILTI tax ,
Income Taxes ,
Legislative Agendas ,
Medicare ,
Political Candidates ,
Political Parties ,
Presidential Elections ,
Tax Policy ,
Tax Rates ,
Tax Reform ,
Value-Added Tax (VAT) ,
Wealth Tax
Recently, several of the presidential candidates and other prominent Democrats have suggested a number of different tax policy proposals, including wealth taxes, mark-to-market taxation, a VAT, additional taxes, increased...more
1/9/2020
/ Bernie Sanders ,
Capital Gains ,
Elizabeth Warren ,
Income Taxes ,
Joe Biden ,
Legislative Agendas ,
Mark-To-Market ,
Political Candidates ,
Political Parties ,
Presidential Elections ,
Tax Rates ,
Tax Reform ,
Value-Added Tax (VAT) ,
Wealth Tax
On October 2, 2019, the Internal Revenue Service (“IRS”) and the U.S. Department of the Treasury (the “Treasury”) issued Revenue Produce 2019-40 (the “Revenue Procedure”) and proposed regulations (the “Proposed Regulations”)...more
11/13/2019
/ Controlled Foreign Corporations ,
Corporate Taxes ,
Financial Services Industry ,
Foreign Corporations ,
Foreign Subsidiaries ,
GILTI tax ,
Income Taxes ,
International Tax Issues ,
IRS ,
Popular ,
Proposed Regulation ,
Revenue Procedures ,
Safe Harbors ,
Subpart F ,
Tax Reform
Recently, several of the presidential candidates and other prominent Democrats have suggested a number of different tax policy proposals, including wealth taxes, mark-to-market taxation, a VAT, additional taxes, increased...more
10/22/2019
/ Bernie Sanders ,
Capital Gains Tax ,
Elizabeth Warren ,
Estate Tax ,
Income Taxes ,
International Tax Issues ,
Kamala Harris ,
Legislative Agendas ,
Mark-To-Market ,
Political Candidates ,
Publicly-Traded Companies ,
Tax Cuts and Jobs Act ,
Tax Policy ,
Tax Reform ,
Value-Added Tax (VAT) ,
Wealth Tax
On June 21, 2019, the United States Supreme Court decided North Carolina Dept. of Revenue v. Kimberly Rice Kaestner 1992 Family Trust (hereinafter, “Kaestner”). In a unanimous opinion delivered by Justice Sotomayor, the Court...more
7/5/2019
/ Beneficiaries ,
Due Process ,
Estate Tax ,
Exclusive Control ,
Forum State ,
In-State Beneficiaries ,
Income Taxes ,
Minimum Contacts ,
North Carolina Department of Revenue v The Kimberley Rice Kaestner 1992 Family Trust ,
SCOTUS ,
State Taxes ,
Trust Distributions ,
Trustees ,
Trusts
On May 13, 2019, the U.S. Internal Revenue Service (“IRS”) and Treasury Department published proposed regulations providing guidance on the rules imposing withholding and reporting requirements under the Code on dispositions...more
5/23/2019
/ FIRPTA ,
Foreign Persons ,
Income Taxes ,
International Tax Issues ,
IRS ,
K-1 ,
Partnerships ,
Proposed Regulation ,
Reporting Requirements ,
Shareholders ,
Withholding Requirements
On March 4, 2019, the Internal Revenue Service (the “IRS”) and the Department of the Treasury (the “Treasury”) released proposed regulations (the “Proposed Regulations”) regarding the deduction for “foreign-derived intangible...more
4/23/2019
/ Controlled Foreign Corporations ,
Corporate Taxes ,
Foreign Corporations ,
Foreign Derived Intangible Income (FDII) ,
GILTI tax ,
Income Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
Proposed Regulation ,
Tax Cuts and Jobs Act ,
Tax Reform
On December 20, 2018, the Internal Revenue Service (the “IRS”) and the Department of the Treasury (the “Treasury”) released proposed “anti-hybrid” regulations (the “Proposed Regulations”) under sections 267A, 245A(e), and...more
1/28/2019
/ Anti-Abuse Rule ,
BEPS ,
Controlled Foreign Corporations ,
Corporate Taxes ,
Dividends ,
Income Taxes ,
IRS ,
Parent Corporation ,
Proposed Regulation ,
Subpart F ,
Tax Reform
On November 26, 2018, the Internal Revenue Service (the “IRS”) and the U.S. Department of the Treasury (the “Treasury”) issued proposed regulations (the “Proposed Regulations”) under section 163(j) of the Internal Revenue...more
12/6/2018
/ Anti-Abuse Rule ,
Business Taxes ,
C-Corporation ,
Controlled Foreign Corporations ,
GILTI tax ,
Income Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
Partnerships ,
PFIC ,
Proposed Regulation ,
REIT ,
REMIC ,
Tax Deductions ,
Tax Planning ,
U.S. Treasury
On August 8, 2018, the U.S. Department of the Treasury (the "Treasury") and the Internal Revenue Service (the "IRS") issued proposed regulations regarding the "pass-through deduction" for qualified trade or business income...more
On Friday December 22, 2017, the President signed into law H.R.1, commonly referred to as the Tax Cuts and Jobs Act (TCJA). This is the most sweeping change to the US federal income tax laws in over three decades, and it will...more
1/17/2018
/ Base Erosion Tax ,
Carried Interest ,
Controlled Foreign Corporations ,
Corporate Taxes ,
EBITDA ,
Foreign Corporations ,
Foreign Taxpayers ,
Income Taxes ,
Pass-Through Entities ,
Tax Cuts and Jobs Act ,
Tax Deductions
The IRS announced yesterday, in IR 2017-210 (the “Advisory”), that state property taxes must be “assessed” in 2017 in order for such taxes to be prepaid in calendar year 2017 and therefore deductible in 2017. The Advisory...more
On Friday, December 15, the U.S. House of Representative and Senate conferees reached agreement on the Tax Cuts and Jobs Act (H.R. 1) (the “Final Bill”), and released legislative text, an explanation, and the Joint Committee...more
12/19/2017
/ 501(c)(3) ,
Affordable Care Act ,
Alternative Minimum Tax ,
Base Erosion Tax ,
Controlled Foreign Corporations ,
Corporate Taxes ,
Deferred Compensation ,
EBITDA ,
Excise Tax ,
Income Taxes ,
Individual Mandate ,
International Tax Issues ,
Legislative Agendas ,
Pass-Through Entities ,
PFIC ,
REIT ,
Section 179 Property ,
Tax Deductions ,
Tax Exempt Entities ,
Tax Rates ,
Tax Reform ,
Tax-Exempt Bonds ,
UBIT
In the early hours of Saturday morning, the U.S. Senate passed the Tax Cuts and Jobs Act (H.R. 1) (the “Senate bill”), just over two weeks after the U.S. House of Representatives passed its own version of the same legislation...more
12/12/2017
/ 401k ,
501(c)(3) ,
501(c)(6) ,
Affordable Care Act ,
Alternative Minimum Tax ,
Base Erosion Tax ,
C-Corporation ,
Controlled Foreign Corporations ,
Corporate Taxes ,
Deferred Compensation ,
EBITDA ,
Excise Tax ,
Income Taxes ,
Individual Mandate ,
International Tax Issues ,
Legislative Agendas ,
Pass-Through Entities ,
PFIC ,
Popular ,
Proposed Legislation ,
REIT ,
Section 1031 Exchange ,
Section 179 Property ,
Tax Deductions ,
Tax Exempt Entities ,
Tax Rates ,
Tax Reform ,
Tax-Exempt Bonds ,
UBIT
House Republican Tax Bill Imposes Excise Tax on Wealthy Private Universities and Excess Compensation of Highly Paid Employees; Subjects State Pension Plans to UBTI Rules -
On Thursday, November 2, House Republicans led by...more
11/7/2017
/ 501(c)(3) ,
Adjusted Gross Income ,
Alternative Minimum Tax ,
Charitable Donations ,
Charitable Organizations ,
Covered Employees ,
Disqualified Persons ,
Educational Institutions ,
Establishment Clause ,
Form 990 ,
Grandfathered Status ,
Highly Compensated Employees ,
Income Taxes ,
IRS ,
Political Speech ,
Private Foundations ,
Proposed Legislation ,
Publicly-Traded Companies ,
Retirement Plan ,
Standard Deduction ,
State and Local Government ,
Tax Deductions ,
Tax Exempt Entities ,
Tax Incentives ,
Tax-Exempt Bonds ,
Tuition ,
UBTI
Yesterday, the Trump Administration, the House Committee on Ways and Means, and the Senate Finance Committee proposed a “unified framework” for tax reform. The members of the working group are House Speaker Paul Ryan (R-WI),...more
9/29/2017
/ Alternative Minimum Tax ,
Business Taxes ,
Corporate Taxes ,
Estate Tax ,
Income Taxes ,
Personal Exemptions ,
Repeal ,
Retirement Plan ,
Standard Deduction ,
Tax Rates ,
Tax Reform ,
Trump Administration
Yesterday the Trump Administration announced the outline of its tax reform proposal. The proposal combines elements of President Trump’s original tax reform proposal announced during the campaign and of the House Republicans’...more
On October 13, 2016, the Treasury Department and the Internal Revenue Service issued final and temporary regulations under section 385 of the Internal Revenue Code. The final and temporary regulations recharacterize certain...more
11/2/2016
/ Acquisitions ,
Bifurcation ,
Corporate Taxes ,
De Minimus Quantity Exemption ,
Debt Instruments ,
Debt-Equity ,
Disregarded Entities ,
Distribution Rules ,
Expanded Group Instruments (EGIs) ,
Income Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
New Regulations ,
S-Corporation ,
Section 385 ,
Securities ,
Stocks