Legal Alert: Special treatment for motor vehicle inventory interest under new federal tax law
View the Eversheds Sutherland Legal Alert summarizing the Tax Act’s effect on motor vehicle dealers here.Conference Sparks Insights from Treasury Regarding New Tax Law
Posted on Jan 29, 2018 in News, Tax Accounting
At an event organized by the District of Columbia Bar Community of Taxation on January 25, 2018, Treasury officials discussed the changes prompted by the recently passed tax legislation and how they affect a variety of different industries and areas. Treasury is prioritizing guidance on changes that have immediate impacts on early financial statements. Among other guidance, Treasury...
IRS is Prioritizing Certain Guidance Related to Pass-through Entities
Posted on Jan 24, 2018 in News, Pass-through Taxation
As the IRS continues to work on guidance for the new tax legislation (formerly known as the Tax Cuts and Jobs Act), the agency is prioritizing certain complex provisions that relate to pass-through entities. In comments to the New York State Bar Association, Clifford Warren, special counsel to the IRS associate chief counsel, identified section 199A (qualified pass-through business...
Treasury Department Releases Notice 2018-13, Providing Additional Guidance on Section 965
Posted on Jan 22, 2018 in International Tax, News
The IRS and Treasury Department have issued additional guidance regarding the transition tax imposed by the tax law’s new section 965. In addition to providing background information on section 965, Notice 2018-13 states that future regulations will be introduced to address: factors for determining a specified foreign corporation; an alternative method for calculating post-1986...
IRS Modifies Notice 1036 Withholding Tables Incorporating Changes to the Individual Tax Rates
Posted on Jan 17, 2018 in Individual Taxation, News
The IRS recently released an updated version of Notice 1036 (includes income tax withholding tables for employers) which integrates the changes made by the recently passed tax legislation. The notice states that employers must implement the withholding tables by February 15, 2018. The IRS anticipates updating its online withholding calculator by the end of February. Read more: New 2018...
Speaker Ryan Foresees only Technical Corrections to the Tax Reform Bill, Rather Than Major Changes
Posted on Jan 16, 2018 in International Tax, News
In an interview with C-SPAN, House Speaker Paul Ryan stated that the bill previously known as the Tax Cuts and Jobs Act would require some technical corrections, such as in the area of international taxation, though he did not offer further details. He anticipates that any corrections to the bill would be small changes. House Ways and Means Committee Chair Keven Brady has also stated...
Broad Scope of “Cash” for Tax on Deferred Foreign Income Impacts Financial Sector
Posted on Jan 10, 2018 in International Tax, News
The new provision requiring that U.S. companies pay a 15.5 percent tax on deferred foreign earnings to the extent of cash and cash equivalents and a 8 percent tax on additional untaxed foreign earnings produces complications for the financial sector. Companies are reporting that the repatriation tax imposes a heavier burden on the financial sector because such companies typically hold...
CRS Report Analyzes 2017 Federal Tax System In Anticipation of Tax Bill Changes
Posted on Jan 9, 2018 in Individual Taxation, Insurance Tax, International Tax, News, Pass-through Taxation
The Congressional Research Service (CRS) published Report 7-5700 on December 26, 2017, which provides an overview of the federal tax system as in effect through 2017. The report notes that the new tax bill, H.R. 1, will generate broad changes for individuals (personal exemptions; standard deduction) and businesses (different tax rate for pass-through business income; territorial tax...
California Proposes Bill to Permit Donations Instead of State Taxes as Challenge to New Federal Tax Bill
Posted on Jan 5, 2018 in News, State and Local Tax
The California legislature has introduced a bill that permits residents to donate to a state “public purpose” fund and receive a dollar-for-dollar tax credit on their returns. This donation is intended to be deductible for federal tax purposes as a means of circumventing the new $10,000 cap on state/local tax deductions included in the recently passed tax bill. White House economic...
Legal Alert: Tax Reform Bill – Changes to Section 529 Qualified Tuition Programs and Section 529A Qualified ABLE Programs
View the Eversheds Sutherland Legal Alert summarizing the principal provisions of the Final Tax Reform Bill affecting Section 529 Qualified Tuition Programs and Section 529A Qualified ABLE Programs here.New York Challenges Federal Government’s Tax Reform Bill as Unconstitutional Double Taxation
Posted on Jan 3, 2018 in News, State and Local Tax
In his recent speech before the state legislature, New York Governor Andrew M. Cuomo stated that the reduction in the state and local tax deduction reflected in the new tax reform bill is unconstitutional double taxation. The governor further indicated that New York would challenge the provision. Cuomo also said that the state will undergo its own tax revision process, shifting away...
IRS Releases Guidance on the Transition Tax Provision
Posted on Jan 2, 2018 in International Tax, News
Last week, the IRS released Notice 2018-07 (the “Notice”), which provides guidance on calculating the so-called “transition tax” of the Tax Cuts and Jobs Act. While the Notice itself does not contain any specific regulations, it does describe the regulations that the IRS plans to issue at a later date, including guidance on the effects that the future regulations will have. The Notice...
Legal Alert: Insurance Industry Provisions in H.R. 1, the Final Tax Bill
View the Eversheds Sutherland Legal Alert discussing the modifications of importance to insurance companies in the Final Tax Reform Bill here.Legal Alert: Party Like it’s 1986: Business Impacts of the Bill Formerly Known as the Tax Cuts and Jobs Act
View the Eversheds Sutherland Legal Alert summarizing the principal provisions of the Final Tax Reform Bill impacting domestic and multinational businesses here.Legal Alert: Section 162(q) Raises Questions about Deductibility of Employment Settlement
Posted on Dec 27, 2017 in Legal Alerts, News
View the Eversheds Sutherland Legal Alert discussing the impact of the Final Tax Reform Bill on the settlement of employment-related claims here.