Our View
Employee Benefits
2021-03-12 – American Rescue Plan saves employers from two months without legislation
2020-08-20 – The emerging patchwork of fiduciary investment advice regulation – Putting the pieces together (update)
2020-08-09 – Trump Administration opens the take-out menu, orders payroll tax relief
2020-06-25 – Buyer beware: tax complications can thwart vacation buyback programs
2020-06-24 – IRS issues guidance on retirement plan CARES Act distributions and loans
2020-03-31 – The CARES Act – Stimulating tax provisions
2019-01-18 – Treasury and IRS issue interim guidance on executive compensation excise tax under section 4960
2018-12-17 – IRS formalizes and provides relief for section 403(b) “once-in-always-in” part-time rule – immediate action required
2018-08-18 – Employee Benefit Arrangements Potentially Affected by Revised UBIT Calculations
2017-12-19 – Compensation and Benefits Provisions in the Final Tax Cuts Bill
2017-11-06 – Tax Cut and Run Employee Benefits Change Under the Tax Cuts and Jobs Act
Energy Tax
2021-10-19 – IRS provides additional guidance on cost of removal, salvage and normalization
2021-07-12 – IRS issues new Section 45Q CCUS ruling
2021-06-30 – IRS extends continuity safe harbor for renewable energy projects
2021-06-01 – FY 2022 Green Book goes big for green energy
2021-04-30 – IRS releases 2021 section 45 production tax credit amounts
2020-09-04 – IRS issues final regulations on section 468A nuclear decommissioning costs
2020-06-12 – Spreading like wildfires—The IRS addresses an atypical “government grant” under IRC Sec. 197
2020-06-30 – Ready, Set, Sequester? An updated guide to the Section 45Q Carbon Capture and Sequestration Credit Guidance
2020-05-22 – Federal Circuit affirms decision regarding developer fees in Section 1603 Renewable Energy Cash Grant Program
2019-12-17 – Congress unveils energy tax extenders
2019-08-07 – Ready, fire, aim – IRS Chief Counsel Advisory misses the mark in NOL carryforward position that contravenes the TCJA
2019-06-07 – IRS releases 2019 section 45 production tax credit amounts
2018-12-07 – Proposed 163(j) regulations provide needed guidance to utilities
2018-02-13 – Energy Tax Extenders Package Passed
2017-12-19 – Final Tax Reform Bill Released – What does it Mean for the Energy Sector?
2017-11-16 – A Comparison of the Energy Tax Changes in the Proposed House and Senate Tax Reform Bills
2017-11-07 – Energy Tax Changes Proposed by House Republicans Tax Reform Bill
General
2021-08-21 – Budget Reconciliation Act I – Setting the Stage: Senate provides slim details of Budget Resolution Agreement
2021-07-15 – Making a Manchin out of a molehill – Senate infrastructure and budget debates heat up
2021-07-08 – Downsizing from a House to a Manchin: Federal and International tax negotiations continue
2021-04-22 – Who in the world is Joe Manchin: International tax proposals vary under Biden, Senate proposals
2021-03-04 – IRS warns taxpayers using obsolete section 199 deductions
2021-01-12 – IRS updates guidance to reflect legislation on expense deductibility under the PPP
2020-08-27 – High time: Final and proposed regulations rework high-tax rule for GILTI and subpart F
2020-08-11 – Corporate provisions in Final Regulations under Section 163(j)
2020-08-11 – IRS representatives give insight into enforcement, implementation of TCJA, CARES Act, and Section 965
2020-03-31 – The CARES Act — Stimulating tax provisions
2019-10-14 – Treasury and the IRS release guidance regarding the repeal of Section 958(b)(4)
2018-11-29 – INXS? IRS issues proposed regulations under section 163(j)
2018-11-15 – IRS and Treasury issue proposed regulations on discounting unpaid losses
2018-09-25 – Legal Alert: GILTI by consolidation
2018-03-06 – Tax Planning in the Age of Tax Reform
2018-01-30 – Special treatment for motor vehicle inventory interest under new federal tax law
2018-01-04 – Tax Reform Bill – Changes to Section 529 Qualified Tuition Programs and Section 529A Qualified ABLE Programs
2017-12-27 – Section 162(q) Raises Questions about Deductibility of Employment Settlements
2017-12-27 – SEC Staff Provides Disclosure and Accounting Guidance in Response to Recent Tax Reform Legislation
2017-12-22 – Party Like It’s 1986: Business Impacts of the Bill Formerly Known as the Tax Cuts and Jobs Act
2017-12-19 – Tax Reform Provisions Affecting BDCs and Closed-End Funds
2017-11-28 – Tax Reform Executive Summary – A 2-Pager on the 7 Things You Need to Know
2017-11-16 – Reconciling the Differences, the Senate Tax Cuts and Jobs Act
2017-11-09 – Sometimes Smaller Is Better—How H.R. 1 Offers Small Businesses Welcome Flexibility
2017-11-07 – How a Framework Becomes a Law: House Republicans Release Tax Reform Bill
Insurance Tax
2021-05-25 – Supreme Court puts IRS on notice [2016-66] in CIC Services, LLC —The Anti-Injunction Act has its limits
2019-07-15 – Long-awaited passive foreign investment company proposed regulations – focus on insurance
2019-06-24 – IRS and Treasury issue final regulations on discounting unpaid losses
2017-11-14 – Tax Cuts and Jobs Bill Update: Major Insurance Industry Changes
2017-11-08 – Tax Cuts and Jobs Bill: Major Insurance Industry Changes
International Tax
2021-08-31 – An incomplete picture: Democratic senators release “framework” for international tax overhaul
2021-04-22 – Who in the world is Joe Manchin: International tax proposals vary under Biden, Senate proposals
2020-09-15 – Say hello to the BEAT waiver: Final regulations adopt and clarify prior proposed regulations
2020-08-27 – High time: Final and proposed regulations rework high-tax rule for GILTI and subpart F
2020-08-11 – IRS representatives give insight into enforcement, implementation of TCJA, CARES Act, and Section 965
2019-12-12 – Changing the BEAT—Final regulations answer key questions, proposed regulations give new relief
2019-03-12 – The Last Piece of the Puzzle—the Section 250 Proposed Regulations
2018-12-20 – And the BEAT goes on – proposed regulations clarify the application of the base-erosion and anti-abuse tax
2018-12-20 – The season of giving – proposed regulations ease FATCA reporting burdens
2018-12-03 – Allocation, apportionment and attribution, oh my – Proposed foreign tax credit regulations provide critical guidance
2018-08-20 – In Transition – Proposed Section 965 Regulations Incorporate and Expand on Prior Guidance
2018-07-19 – Ireland after US Tax Reform – What Does it Mean for Business?
2018-4-09 – Transition Tax – enough about how it works; here is what doesn’t work
2017-12-19 – Following the Senate’s Lead – The International Tax Provisions for the Final Bill
2017-11-22 – Worldwide Territoriality: International Tax Proposals Broaden the Base
State and Local Tax
2020-04-22 – Down a rabbit hole: New Jersey regulations provide guidance on GILTI and FDII apportionment
2020-04-03 – TCJA’s NOL limitations rolled back in congressional COVID-19 response
2019-06-21 – New York Legislation excluding 95% of GILTI awaits governor’s signature
2019-01-14 – Legal Alert: New York instructs taxpayers on GILTI apportionment
2018-12-24 – It’s Not the Eggnog – New Jersey Proposes to Specially Allocate GILTI Based on GDP
2018-12-18 – Consolidated complexities – state corporate income tax implications of I.R.C. § 163(j)
2018-06-12 – New York Bill Introduced to Exempt GILTI
2018-05-24 – IRS to Crackdown on SALT Deduction Cap Workarounds
2018-04-02 – New York State Budget Adopts Substantial Changes in Response to Federal TCJA
2018-03-21 – Georgia Passes Legislation to Provide Deduction of GILTI from the State Tax Base
2018-02-05 – Will Georgia Conform to Federal Tax Reform? Annual Legislation Introduced
2017-11-10 – The State and Local Tax Implications of Federal Tax Reform
Tax Accounting
2021-08-17 – Rev. Proc. 2021-34, IRS guidance for implementing the final Section 451 regulations
2020-12-29 – IRS provides welcome flexibility and clarification in final small business tax accounting regulations
2020-12-22 – IRS fails to realize certain income recognition issues in final section 451 regulations
2020-04-16 – IRS releases Rev. Proc. 2020-22 enabling taxpayers to fully utilize changes made by the CARES Act to Section 163(j)
2020-04-03 – Surprise! Section 901(m) final regulations
2019-09-13 – Legal Alert: Timing is everything – Treasury and IRS propose regulations under Section 451(b)
2018-12-05 – IRS and Treasury issue final regulations on negative adjustments under UNICAP
2018-10-16 – Comments on the Proposed Regulations Under Section 168(k)
2018-05-18 – IRS Releases Automatic Changes in Methods of Accounting List
2018-04-24 – IRS Releases Fact Sheet on Depreciation
2017-12-20 – The Tax Cuts and Jobs Act, Final Cut: A Methods-Based Review of the Tax Bill
2017-11-28 – The Tax Cuts and Jobs Act, Take Three: A Methods-Based Review of the Senate’s Initial Draft of Tax Reform Legislation
2017-11-13 – The Tax Cuts and Jobs Act, Take Two: A Methods-Based Comparison of the Senate and House’s Tax Reform Plans
2017-11-07 – The Tax Cuts and Jobs Act, Take One: A Methods-Based Overview of the Initial Draft of the House Tax Bill