Six Main Areas Identified For TCJA International Guidance
Posted on Jul 5, 2018 in International Tax, News
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
Posted on Jul 5, 2018 in Employee Benefits, News
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...
Legislation for Phase 2 of Tax Reform Expected in August
Posted on Jun 18, 2018 in News
House Ways and Means Committee Chair Kevin Brady indicated that Republicans hope to have a proposal for healthcare and additional tax changes by August. While the contents of the bill remain uncertain, potential topics include: permanent individual income tax provisions, retirement savings, the treatment of capital gains, and employer incentives for helping to pay back student loan...
Committee Hearing Discusses Tax Reform Impact and Next Steps
Posted on May 21, 2018 in International Tax, News
The House Ways and Means Committee held a hearing last Wednesday, May 16th, where Republicans and Democrats continued to be divided in their evaluations of the recent tax reform and its effects on jobs, the economy, and investment. In opening statements, Richard Neal criticized the new law for giving “83 percent of the tax savings to the top one percent.” Testimony during the hearing...
No Rules or Answers: Notices to Just Provide Notice
Posted on May 11, 2018 in News, Tax Accounting
Rather than provide “subregulatory guidance” or answer specific questions, future notices will simply notify taxpayers of regulations to come. According to Catherine Hughes of the Treasury’s Office of Tax Policy, the Treasury and IRS will not create new rules, but give a “heads up” of what proposed regulations are in the works. This has been seen in recent notices, including Notice...
Notice Confirms Business as Usual for Taxpayers with Advance Payments
Posted on Apr 16, 2018 in News, Tax Accounting
The IRS issued Notice 2018-35 on April 13, which permits taxpayers to continue to rely on Rev. Proc. 2004-34 for the treatment of advance payments under Section 451. According to the Notice, the IRS will not challenge taxpayers’ use of the current guidance that provides for the limited deferral of advance payments. Additionally, the Notice requests comments with suggestions on Section...
Videocast: Implications of tax reform on income recognition
Posted on Apr 2, 2018 in Tax Accounting
The changes made to the Internal Revenue Code by the Tax Cuts and Jobs Act (TCJA) included a number of modifications to the rules associated with income recognition. Although the TCJA codified certain taxpayer-favorable methods (i.e., the Deferral Method under Rev. Proc. 2004-34), the revised Section 451(b) likely will result in an acceleration of taxpayers’ historic recognition of...
“Phase Two” of Tax Cuts to Offer Permanence
Posted on Mar 19, 2018 in Individual Taxation, News
Congressional Republicans and the White House are pushing to pass another tax package this year to make permanent the recently enacted benefits for families and small businesses. House Ways and Means Committee Chairman Kevin Brady stated that a second tax bill would provide a permanent extension to the individual tax cuts, the majority of which currently expire after 2025. These tax...
The Treasury Department Anticipates Releasing a Notice on IRC 163(j) in the Near Future
Krishna Vallabhaneni, Treasury deputy tax legislative counsel, recently stated that the Treasury Department plans on issuing a notice in the coming weeks to address some of the recent issues related to amended IRC 163(j) (interest expense deductions). Some of the specific issues the notice will address include the treatment of carryovers and limitations under the previous section...Regulations and Notices to Provide Guidance on New Tax Bill
Posted on Feb 5, 2018 in International Tax, News
As the early guidance period for the new tax bill continues, the Treasury and IRS plan to shift to focusing on developing regulations over the next six months. A less notice-oriented approach is expected, with only five to ten limited-scope notices addressing basic questions, such as section 163(j) business interest issues, anticipated. IRS and Treasury tax reform projects will be...
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...
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...
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...
Legal Alert: The Tax Cuts and Jobs Act, Final Cut: A Methods-Based Review of the Tax Bill
View the Eversheds Sutherland Legal Alert discussing the particular provisions of the Final Tax Reform Bill that fall under the umbrella of income tax accounting and accounting methods, and the potential impact such reforms will have on corporate taxpayers, here.Legal Alert: Tax Reform Provisions Affecting BDCs and Closed-End Funds
Posted on Dec 19, 2017 in Legal Alerts, News
View the Eversheds Sutherland Legal Alert discussing important developments that may affect closed-end funds, including business development companies (BDCs), and the portfolio companies in which closed-end funds invest, in the Final Tax Reform Bill here.