House Approves Three New Tax Bills
Posted on Sep 28, 2018 in Individual Taxation, News
On September 27, 2018, the House approved two bills that are part of a second package of tax law changes advanced by House Republicans (“Tax Reform 2.0”). The first bill would create universal savings accounts, expand the utility of section 529 education savings plans, and make the offering of employee retirement plans more accessible for small businesses. The second bill would provide...
IRS to Issue Proposed Regulations on Market Discount
Posted on Sep 27, 2018 in News, Tax Accounting
The IRS and Treasury Department have recently announced (Notice 2018-80) that they plan to issue guidance providing that market discount is not includible in income under section 451(b), which was added to the Code by the Tax Cuts and Jobs Act. Under section 451(b), accrual method taxpayers generally must include an amount in gross income no later than when it is included in income in...
House to Vote on Tax Reform 2.0 on Thursday and Friday
House Ways and Means Committee Chair Kevin Brady recently stated the House votes for Tax Reform 2.0 are scheduled to occur on Thursday and Friday. H.R. 6757, the Family Savings Act of 2018, and H.R. 6756, the American Innovation Act of 2018, are scheduled for votes on Thursday. H.R. 6760, the Protecting Family and Small Business Tax Cuts Act of 2018, is scheduled for vote on Friday....Tax Reform 2.0 Will Likely Not Be Passed By Congress Before Midterms
House Ways and Means Committee Chair Kevin Brady recently stated that the three tax bills that together comprise the new tax reform package will likely not get through the Senate before midterm elections. The House Ways and Means Committee previously passed the bills through committee. The House is expected to vote the legislation later this month. Read More: Top House tax writer Kevin...Proposed GILTI Regulations Released
Posted on Sep 13, 2018 in International Tax, News
The IRS has released proposed regulations on global intangible low-tax income (GILTI) under section 951A, a provision added by the Tax Cuts and Jobs Act. The proposed regulations set forth rules for calculating the GILTI inclusion and new reporting requirements, but do not address foreign tax credit rules, which will be addressed separately in the future. Public comments on the...
Tax Reform 2.0 Approved by House Ways and Means Committee
The House Ways and Means Committee approved the Tax Reform 2.0 package consisting of three bills. This overhaul package would make permanent the TCJA’s reduced rates for individuals along with several other provisions, including the $10,000 cap on the state and local tax (SALT) deduction, and the 20% deduction on certain pass-through business income. A proposed amendment to repeal the...IRS Releases Draft Forms for Transition Tax and BEAT Reporting
Posted on Sep 10, 2018 in International Tax, News
The IRS released draft forms for reporting a taxpayer’s section 965 transition tax and section 59A base erosion and anti-abuse tax liabilities. The forms, titled Form 965 (“Inclusion of Deferred Foreign Income Upon Transition to Participation Exemption System”) and Form 8991 (“Tax on Base Erosion Payments of Taxpayers With Substantial Gross Receipts”), respectively, can be found on the...
GILTI Regulations Reviewed by OMB
Posted on Sep 10, 2018 in International Tax, News
The Office of Management and Budget (OMB) has completed its review of global intangible low-tax income (“GILTI”) proposed regulations. Section 951A, enacted by the Tax Cuts and Jobs Act, generally taxes income earned by controlled foreign corporations at a reduced rate. Read more: OMB Completes Review of Regs on GILTI
Draft of Tax Reform 2.0 Introduced in Congress
House of Ways and Means Committee Chair Kevin Brady recently highlighted the introduction of three new tax bills that together comprise the new tax reform package. The drafts of new tax legislation deal primarily with individuals, retirement savings, and small businesses. H.R. 6760, the Protecting Family and Small Business Tax Cuts Act of 2018, would extend the 20 percent deduction on...Tax Reform 2.0 to be Marked Up This Thursday
According to its Chairman Kevin Brady, the House Ways and Means Committee will consider and mark-up “Tax Reform 2.0” legislation this Thursday. Released early last week, the Tax Reform 2.0 package consists of three bills to make permanent the individual tax cuts, pass-through provision under Section 199A and state and local tax (SALT) deduction cap added by the Tax Cuts and Jobs Act....Legal Alert: Real estate unlocked: Opportunity zones offer tax incentives to investors
Posted on Sep 7, 2018 in Legal Alerts, Uncategorized
As part of the Tax Cuts and Jobs Act of 2017, Congress added new rules to the Internal Revenue Code intended to promote investments in low-income communities designated as “qualified opportunity zones.” Deferral of tax on gains reinvested in Opportunity Funds and reduction or elimination of tax on such investments held for extended periods are the OZ Program’s carrots. Qualifying real...
Comments on Sections 162 and 6050X Requested by IRS
Posted on Sep 4, 2018 in News, Tax Accounting
The IRS has invited the public to comment on transitional guidance for the new reporting requirements under section 162(f) and new section 6050X, which was added by the Tax Cuts and Jobs Act, with respect to fines, penalties and other amounts. The comment period is open through November 5, 2018. Read the Notice here: Notice 2018-19172 Read more here: IRS Seeks Comment On Planned Biz...