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Multinationals Face An Irrevocable Decision Under The New Section §163j Proposed Regulations
Since the 2017 tax act enacted the new §163(j) limitation on interest deductions, multinationals have been asking whether the limitation applies to controlled foreign
United States
23 Jul 2019
The BEAT Proposed Regulations: Use Of Common Law Doctrines
With its new reach, the Base Erosion and Anti-Abuse Tax ("BEAT") under Section 59A has now come into sharp focus for many large corporate taxpayers, particularly in light of the phase in of the 10%
United States
29 May 2019
Proposed FDII Regulations Bring Some Clarity
On March 4 Treasury and the IRS released the highly anticipated proposed foreign-derived intangible income regulations (REG-104464-18) under section 250.
United States
29 Apr 2019
IRS Filing And Reporting Requirements For ISO Exercises And ESPP Stock Transfers For 2019
This client alert is intended to remind you of certain 2018 year-end reporting requirements under Section 6039 of the Internal Revenue Code of 1986, as amended (the Code)
United States
24 Jan 2019
Treasury And IRS Propose Welcome (And Some Unwelcome) Guidance On The Base Erosion And Anti-Abuse Tax
Treasury and the IRS have issued proposed regulations filling a number of gaps and providing necessary guidance on the Base Erosion and Anti-Abuse Tax (BEAT).
United States
17 Jan 2019
The High-Taxed Exception And E&P Limitation To Subpart F Income
Subpart F has long included exceptions to subpart F income for income of controlled foreign corporations ("CFCs") subject to a relatively high rate of foreign tax and limited subpart F inclusions to the current earnings and profits ("E&P") of the CFC.
United States
9 Jan 2019
IRS Issues New Guidance On Section 83(i)
The test is not whether 80 percent received either options or RSUs.
United States
27 Dec 2018
The New Foreign Tax Credit Proposed Regulations – An Executive Summary
Released on November 30, 2018, the foreign tax credit proposed regulations provide a comprehensive new framework for calculating the foreign tax credit in light of several changes made by the Tax Cuts
United States
18 Dec 2018
Impact Of Tax Reform On The Purchase And Sale Of Controlled Foreign Corporations — Selected Considerations
The application of §1248 and §338(g) in the context of the purchase or sale of a controlled foreign corporation (CFC) has long been one of the most complex areas of the tax code. The recently enacted...
United States
20 Sep 2018
New 162(m) Guidance: IRS Notice 2018-68 Clarifies Scope Of Tax Reform And Transition Rules
Section 162(m) of the Internal Revenue Code denies a tax deduction to a public company for compensation paid to certain individuals—called "covered employees"—to the extent that the compensation paid
United States
3 Sep 2018
US Taxation Of IP After Tax Reform
U.S. taxation of intellectual property has become astoundingly more complex after the Tax Cuts and Jobs Act. The new rules are so complex that the IRS and Treasury are still figuring out...
United States
13 Jul 2018
New Field Attorney Advice Explores The Intersection Of § 1253 With The Anti-Churning Rules Of § 197
A new IRS legal advice memorandum addresses a fact pattern that may become more common in the wake of Tax Reform and highlights the potential application of Code § 1253 to change the tax results...
United States
2 Jul 2018
International Tax Reform For US Individuals And Pass-Through Entities (Video)
The recent Tax Cuts and Jobs Act has revolutionized the U.S. taxation of international income earned from outbound investment and business operations.
United States
17 May 2018
IRS Notice 2018-26: Important New Guidance On The Mandatory Repatriation Tax
This document discusses Notice 2018-26, the third IRS Notice providing guidance on the new mandatory repatriation tax under § 965.
United States
11 Apr 2018
What Private Companies & Investors Should Know About Qualified Small Business Stock (Video)
Only certain types of companies qualify under the QSBS rules which are laid out by a statute that aims to encourage entrepreneurial ventures
United States
13 Mar 2018
IRS Filing And Reporting Requirements For ISO Exercises And ESPP Stock Transfers - January 12, 2018
This client alert is intended to remind you of certain 2017 year-end reporting requirements under Section 6039 of the Internal Revenue Code of 1986, as amended (the Code)...
United States
15 Jan 2018
A Concise Summary Of The New Tax Law
Those far-off changes are not addressed in this summary.
United States
8 Jan 2018
Congress Approves Tax Reform Bill Impacting Equity Compensation
The Tax Cuts and Jobs Act was passed by both chambers of Congress on Wednesday, December 20, 2017, and will be sent to the President's desk for final signature.
United States
22 Dec 2017
Equity Compensation Rules Continue To Change In Latest Proposed Tax Reform Bill
The tax reform bill passed by the Senate early Saturday morning, December 2, in a 51-49 vote contained a number of last-minute amendments which, among other things ...
United States
7 Dec 2017
Revised Senate Tax Reform Bill Represents Win for Technology Sector
Paving the way for a net-win for technology companies, Senate Finance Committee Chairman Orrin Hatch (R-Utah) released a modified chairman's mark to the Tax Cuts and Jobs Act ...
United States
20 Nov 2017
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