Eversheds Sutherland Tax Reform Law Blog
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LB&I Division Announces Campaign Targeting Transition Tax Compliance

On July 2, 2018, the Internal Revenue Service’s Large Business and International Division announced a compliance campaign focused on the transition tax provisions of section 965, enacted by the 2017 Tax Act. Section 965 generally requires that U.S. shareholders pay a tax on the untaxed foreign earnings of certain specified foreign corporations. The compliance campaign serves as a...

Six Main Areas Identified For TCJA International Guidance

In anticipation of tax reform 2.0, six major international areas have been identified as prime for regulatory focus and guidance: the allocation of expenses to GILTI income; the application of the accumulated earnings tax under section 531 to GILTI;  treatment of consolidated tax return filers for GILTI purposes; potential carve-outs to the base erosion and anti-abuse tax (or BEAT);...

Phase Two of Tax Reform Will Retain Pretax Benefits of 401(k) Plans

A spokesperson from the House Ways and Means Committee recently stated that the new tax proposals will not revise the pretax treatment of 401(k) savings plans. House Ways and Means Committee Chairman Brady previously stated, in an interview, that the phase 2 tax proposal might address retirement and include a savings element. Read More: Ways & Means Quashes Rothification Concerns...

Trump Anticipates Tax Reform 2.0 in October

President Trump, during an interview with Fox Business Network’s Maria Bartiromo, stated that he expects another tax overhaul to be proposed in October.  As part of the reform plan, President Trump is considering a further reduction of the recently enacted 21 percent corporate tax rate, to 20 percent. Read more here:  Trump expects another tax overhaul, says ‘probably in...


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