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IRS Issues Proposed Regulations on the Expanded Definition of "Covered Employee" Under Code Section 162(m)

On January 16, the Internal Revenue Service (IRS) published proposed regulations ( 90 FR 4691) under Section 162(m) of the Internal Revenue Code. Section 162(m) generally limits the deductibility of compensation paid in any...more

Tracking Tax Reform: [Un]Intended Consequences For The ACA

Late at night on December 14, 2018, Judge Reed O’Connor of the U.S. District Court for the Northern District of Texas issued his decision in Texas v. U.S., No. 4:18-cv-00167, that the individual mandate under the Affordable...more

Tracking Tax Reform IRS Issues Initial Guidance Under Section 162(m)

On August 21, 2018, the IRS issued Notice 2018-68 providing initial guidance on the amendments made to Section 162(m) of the Internal Revenue Code of 1986 (the “Code”) by the 2017 tax reform bill, which has been renamed “To...more

Tracking Tax Reform: Capital Gains from Certain Partnership Profits Interests Subject to Extended Holding Period for Favorable Tax...

Under the “Tax Cuts and Jobs Act”, the recently enacted federal tax reform legislation (the “Act”), a new limitation applies to profits interest awards. Under the Act, income from “applicable partnership interests” will not...more

Tracking Tax Reform: The Executive Compensation and Employee Benefit Provisions of The Tax Bill

On December 20, 2017, the House of Representatives and the Senate voted to enact the tax reform bill, which has been renamed “To provide for reconciliation pursuant to titles II and V of the concurrent resolution on the...more

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