Eversheds Sutherland Tax Reform Law Blog
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Treasury Department Releases Notice 2018-13, Providing Additional Guidance on Section 965

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...

Speaker Ryan Foresees only Technical Corrections to the Tax Reform Bill, Rather Than Major Changes

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

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

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...

IRS Releases Guidance on the Transition Tax Provision

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: 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: Following the Senate’s Lead – The International Tax Provisions in the Final Bill

View the Eversheds Sutherland Legal Alert focusing on the international tax provisions in the Final Tax Reform Bill here.

Legal Alert: Worldwide Territoriality: International Tax Proposals Broaden the Base

View the Eversheds Sutherland Legal Alert focusing on international tax reform proposals in the House Plan and the Senate Plan here.

Orrin Hatch to introduce Senate tax reform bill amendments changing 401(k), IRA classifications

The Senate Finance Committee has released a full list of the proposed amendments to the Tax Cuts and Jobs Act currently under consideration. Chairman Senator Orrin Hatch will present several amendments to the Senate’s tax reform bill during the mark up. His proposal includes a provision allowing publicly traded companies to deduct up to 12.5% of dividends paid to shareholders from...

Ways and Means Committee Amends the Tax Cuts and Jobs Act

On Monday, the House Ways and Means Committee approved an amendment offered by Kevin Brady to the proposed tax reform bill. The amendment revises the rules targeting the international base erosion by providing a foreign tax credit, among other items. This amendment also imposes an additional holding period requirement for capital gain on carried interest, increasing the holding period...

Senate Finance Committee Holds Hearing on International Tax Reform

Led by Chairman Hatch, the Senate Finance Committee held a hearing on international tax reform, following the release of the Republican tax reform framework. The hearing and witnesses focused on the competitive disparity between foreign multinationals and domestic multinationals. The witnesses differed on whether a switch to a territorial system or stronger earning stripping provisions...

Business Community Urges Congress to Pass Tax Reform

Corporate America is encouraging Congress to pass tax reform legislation as quickly as possible.  Amid apprehension that tax reform could experience delays similar to those facing other items on the Republican agenda, business leaders have pressed congressional leaders to move forward with a budget resolution to facilitate tax reform.  Business groups will launch campaigns during...

Hatch Assigns Republican Committee Members to Specific Tax Reform Items

Senator Hatch, head of the Senate tax-writing panel, asked Republican members of the committee to provide input on specific tax areas: Senators Mike Enzi of Wyoming and Rob Portman of Ohio will focus on international business taxation; Senator Chuck Grassley of Iowa will focus on taxation of individuals; Senator John Thune of South Dakota will focus on business and estate taxes;...

Automotive Industry Leaders Opposed to Border Adjustment Tax

Representatives in the automotive industry met with Gary Cohn, the White House National Economic Council Director, yesterday to discuss the House Republicans’ proposed border adjustment tax. President of the American International Automobile Dealers Association, Cody Lusk, expressed the industry’s dissatisfaction with the plan, which they believed would drive up the cost of every...

House Ways and Means Committee Holds First Hearing on Tax Reform.

Led by Chairman Brady, the House Ways and Means Committee held its first hearing on tax reform Thursday. The hearing and witnesses focused mainly on provisions advanced by House Republicans in their Blueprint, including immediate expensing and the impact of a lower corporate tax rate on investment and manufacturing. The witnesses testifying before the Committee included: John J....


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