Hearing on Proposed Regulations for Limitation on Deduction for Business Interest Expense – Treasury and IRS Hear Targeted, Industry-Specific Requests
Posted on Feb 28, 2019 in Uncategorized
On February 27, 2019, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) held a hearing on the proposed regulations for the section 163(j) limitation on deduction for business interest expense (the Proposed Regulations), which were released on November 28, 2018. Nine witnesses, including Eversheds Sutherland Partner Wes Sheumaker, provided a variety of...
Hearing on Proposed Qualified Opportunity Zone Regulations – Requests for Greater Flexibility
Posted on Feb 15, 2019 in Uncategorized
On February 14, 2019, the Internal Revenue Service (IRS) and the Department of the Treasury (Treasury) held a hearing on the proposed regulations for the Qualified Opportunity Zone (QOZ) program (the Proposed Regulations), which were released on October 19, 2018. More than 20 witnesses provided comments and recommendations on a variety of topics, generally stressing a desire for...
Georgia Bill Proposes Changes to Sales and Use Tax Reporting and Collection Rules
Posted on Feb 15, 2019 in State and Local Tax
On February 14, 2019, the Georgia House Ways and Means Committee voted in favor of House Bill 182. Effective for January 1, 2020, the bill would amend O.C.G.A. § 48-8-2(8)(M.1) to lower the sales threshold on the requirement to collect or report sales and use tax from $250,000 to $100,000 and would repeal subsection (c.2) of O.C.G.A. § 48-8-30 in its entirety to eliminate the option to...
OECD Proposal
Posted on Feb 14, 2019 in Uncategorized
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Podcast: New Jersey apportionment of GILTI
Posted on Feb 6, 2019 in State and Local Tax
In this podcast, our state tax team discusses New Jersey guidance regarding the apportionment treatment of GILTI income.
New Jersey Tax Court Rejects Alternative Apportionment Formula
Posted on Feb 1, 2019 in State and Local Tax
The New Jersey Tax Court rejected the Division of Taxation’s application of a five-factor alternative apportionment formula as invalid rulemaking under New Jersey’s Administrative Procedures Act (APA). The Tax Court previously determined that an application of the statutory apportionment formula in effect prior to 2011 for companies without a “regular place of business” outside New...
Legal Alert: We are not in Kansas anymore – OECD proposes way forward for digital tax solution
Posted on Feb 1, 2019 in Uncategorized
The OECD has again weighed in on the question of taxation of the digital economy, following on its original report as part of Action 1 of the BEPS initiative. On January 29, 2019, the OECD issued a policy note that sets out two “pillars” to evaluate proposals for a global digital tax solution. The first pillar focuses on the allocation of taxing rights. The second pillar focuses on...