News & Analysis as of

Tax Cuts and Jobs Act Tax Planning Proposed Regulation

Morgan Lewis - ML Benefits

IRS Proposes Regulations on Expanded Definition of Covered Employee Under Code Section 162m

Section 162(m) of the Internal Revenue Code prohibits a publicly held corporation from taking compensation-related tax deductions with respect to the compensation of a “covered employee” to the extent the compensation exceeds...more

McDermott Will & Schulte

Weekly IRS Roundup December 26 – December 30, 2022

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of December 26, 2022 – December 30, 2022...more

Tucker Arensberg, P.C.

Gifting and Estate Tax in Period of Big Changes

Tucker Arensberg, P.C. on

​​​​​​​The Tax Cuts and Jobs Act of 2017 increased the federal estate and gift tax exclusion amount (sometimes called the “basic exclusion amount” or “BEA”) from $5 million to $10 million. (Those numbers are adjusted for...more

Davis Wright Tremaine LLP

Not So Fast! IRS Releases Proposed Clawback Regulations

The IRS recently released proposed clawback regulations on the treatment of gifts that are complete at the time of transfer but are potentially included in the donor's gross estate at death. Such gifts will likely get the...more

Harris Beach Murtha PLLC

IRS Looks to Limit Estate Tax Break For Large Gifts in Tweak to Anti-Clawback Regulations

The Treasury Department issued proposed regulations on Tuesday, April 26, 2022 in follow up to the anti-clawback regulations published on November 26, 2019. The 2019 anti-clawback regulations were in response to the Tax Cuts...more

Lowndes

Bipartisan Bill Proposes Changes to Opportunity Zone Benefits

Lowndes on

If you acquired or built a senior living facility that is located in an opportunity zone, or are considering doing so, a recent bipartisan bill introduced in Congress proposes making changes to the opportunity zone rules. ...more

Skadden, Arps, Slate, Meagher & Flom LLP

IRS Final Regulations on Timing of Income Recognition Provide Much-Needed Clarity, But Leave Some Questions Unanswered

On December 21, 2020, the Treasury Department (Treasury) and the IRS released final regulations (Regulations) under Section 451 for determining the taxable year in which an amount must be reported as gross income on the...more

Troutman Pepper Locke

Structuring Sales of Investments by Funds After the Proposed Section 1061 Regulations

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Introduction - Gain of a fund or other investment partnership from a capital asset sale held for over one year is taxed to the fund’s partners at favorable long-term capital gains rates. Until 2018, this general rule...more

Bilzin Sumberg

IRS Issues Final Downward Attribution Regulations

Bilzin Sumberg on

On September 21, 2020, the IRS finalized (with certain modifications) proposed regulations that had been issued last year regarding some of the unintended consequences of the downward attribution rules under Section 958(b)....more

Vinson & Elkins LLP

[Webinar] All in the Family: Applying the Business Interest Expense Limitation Within Groups - September 30th, 12:00 pm - 1:00 pm...

Vinson & Elkins LLP on

The 2017 Tax Cuts and Jobs Act generally limits the amount of business interest expense that a taxpayer may deduct. This webinar will cover newly issued final and proposed Treasury regulations under section 163(j), with a...more

Littler

IRS Issues Proposed Rule on Business Expense Deductions

Littler on

On February 26, 2020, the IRS published proposed regulations implementing changes made by the Tax Cuts and Jobs Act of 2017 (TCJA) regarding the elimination of deductions for entertainment and the limitation on food and...more

Sullivan & Worcester

20 Ozone Things to Know for 2020 (Part 1)

Sullivan & Worcester on

Two months have elapsed since Treasury and IRS issued the Final Regulations on Opportunity Zones. The effective date is March 13, 2020. During these two months, the Sullivan Ozone Practice Group has hosted gatherings for our...more

Troutman Pepper Locke

IRS Issues Proposed Regulations On Section 162(M)'s Executive Compensation Deductibility Cap

Troutman Pepper Locke on

On December 20, 2019, the IRS issued proposed regulations under Section 162(m) of the Internal Revenue Code....more

Jackson Walker

Treasury Releases Final Regulations for Investing in Qualified Opportunity Zones

Jackson Walker on

On December 19, 2019, the Treasury Department released final regulations on the Qualified Opportunity Zone (QOZ) program first enacted in the Tax Cuts and Jobs Act of 2017. Final regulations provide additional safe harbors...more

Fenwick & West LLP

Treasury and IRS Release Final and Proposed Foreign Tax Credit Regulations

Fenwick & West LLP on

On December 2, 2019, Treasury and the IRS released final and proposed regulations on the foreign tax credit. As expected, the final regulations finalize the 2018 proposed regulations relating mainly to the Tax Cuts and Jobs...more

McDermott Will & Schulte

Weekly IRS Roundup December 23 – 27, 2019

McDermott Will & Schulte on

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of December 23 – 27, 2019. December 20, 2019: The Department of the Treasury’s Financial Crimes...more

McDermott Will & Schulte

Weekly IRS Roundup December 16 – 20, 2019

McDermott Will & Schulte on

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of December 16 – 20, 2019. December 16, 2019: The IRS released a notice extending the phase-in...more

Herbert Smith Freehills Kramer

New Section 162(m) Proposed Regulations

The Tax Cuts and Jobs Act of 2017 (TCJA) made significant changes to Section 162(m) of the Internal Revenue Code (Section 162(m)), expanding the scope of individuals and entities subject to Section 162(m), in addition to...more

McDermott Will & Schulte

Proposed Foreign Tax Credit Regulations Provide New Rules for Allocation and Apportionment of Deductions and Creditable Foreign...

McDermott Will & Schulte on

The Treasury Department and the IRS have issued highly anticipated guidance in the area of stewardship expenses and R&D expenses. The 2019 Proposed Regulations also provide extensive guidance on allocating and apportioning...more

Proskauer Rose LLP

Personal Planning Strategies - December 2019

Proskauer Rose LLP on

Estate, Gift and GST Tax Update - What This Means for Your Current Will, Revocable Trust and Estate Plan - The estate and gift tax regimes have been permanent and unified since the passage of The American Taxpayer...more

McDermott Will & Schulte

Weekly IRS Roundup November 4 – 8, 2019

McDermott Will & Schulte on

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of November 4–8, 2019. November 4, 2019: The IRS posted a new Large Business and International...more

McDermott Will & Schulte

Weekly IRS Roundup October 7 – October 11, 2019

McDermott Will & Schulte on

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of October 7 – October 11, 2019. October 7, 2019: The IRS announced that taxpayers who requested...more

McDermott Will & Schulte

Weekly IRS Roundup September 30 – October 4, 2019

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of September 30 – October 4, 2019. September 30, 2019: The IRS published a draft of the tax year...more

Shumaker, Loop & Kendrick, LLP

The Estate Planner - November/December 2019

What’s a clawback ? and should you be worried about it? By temporarily doubling the gift and estate tax exemption amount, the Tax Cuts and Jobs Act created an historic opportunity for affluent families to shelter wealth...more

Skadden, Arps, Slate, Meagher & Flom LLP

New IRS Rules on Timing of Income Recognition Raise Questions

On September 5, 2019, the Treasury Department (Treasury) and the IRS released proposed regulations (Regulations) that would impact when accrual method taxpayers report amounts in gross income. Generally, Section 451 provides...more

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