On October 3, the Internal Revenue Service (IRS) issued Notice 2018-76 (the Notice) to address the deductibility of business meals under section 274(a) of the Internal Revenue Code. The Tax Cuts and Jobs Act (the TCJA) made...more
Last year, the federal government enacted the most substantial tax reform legislation since 1986 in Public Law 115-97, commonly referred to as the Tax Cuts and Jobs Act of 2017 (TCJA). Of the many business-friendly changes,...more
On June 21, 2018, the Internal Revenue Service (IRS) issued Chief Counsel Advice (CCA) 2018-30-011, which disallowed a taxpayer’s deduction of a portion of a success-based fee incurred in a corporate transaction because the...more
The Treasury Department and the Internal Revenue Service (IRS) issued Notice 2018-26, which provides guidance under section 965 of the Internal Revenue Code regarding the “transition tax.” Section 965 imposes a transition tax...more
4/10/2018
/ Accounting Methods ,
Controlled Foreign Corporations ,
Corporate Taxes ,
Foreign Earned Income ,
Foreign Subsidiaries ,
Income Taxes ,
International Tax Issues ,
IRS ,
Shareholders ,
Subpart F ,
Tax Rates
On March 13, 2018, the Large Business and International (LB&I) Division of the Internal Revenue Service (IRS) announced five new compliance campaigns. The announcement of these new campaigns reiterates LB&I’s efforts to focus...more
On December 22, 2017, the President signed into law the Tax Cuts and Jobs Act (the TCJA), the most substantial overhaul of the Internal Revenue Code since 1986. The TCJA significantly changes how the US taxes individuals,...more
On November 2, 2017, the House Ways and Means Committee released a draft of the Tax Cuts and Jobs Act (the House proposal). On November 9, Senate Finance Committee (SFC) Chairman Orrin Hatch (R-UT) released a summary of the...more
On November 9, 2017, the Senate Finance Committee (SFC) released a summary of its initial draft tax proposal (the Senate proposal). While the Senate proposal is similar to the House Ways and Means Committee’s proposal (the...more
On October 23, 2017, the Internal Revenue Service Office of Chief Counsel (Chief Counsel) concluded that certain merchant discount fees earned by a parent company in a consolidated group did not constitute domestic production...more
On April 19, 2017, the Internal Revenue Service (IRS) released Rev. Proc. 2017-30, 2017-17 I.R.B. 1, which provides an updated list of automatic changes in methods of accounting. As was the case with its predecessor, Rev....more
In the last few weeks, the Internal Revenue Service (the Service) issued several private letter rulings addressing a variety of tax accounting issues. From bonus depreciation elections to the correct unit of property for...more
On July 6, the Internal Revenue Service (IRS) Large Business and International Division issued a Directive1 to IRS agents regarding how to determine when a major component pertaining to steam or electric generation property...more