Legal Alert: BEAT, FATCA and Insurance—proposed regulations clarify the application of the BEAT and the treatment of insurance premiums under FATCA
Posted on Dec 21, 2018 in Legal Alerts
On December 13, 2018, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued two sets of proposed regulations of importance to insurance companies. One set was the long-awaited regulations under section 59A of the Internal Revenue Code of 1986, as amended (Code), commonly referred to as the base-erosion anti-abuse tax (BEAT). The other set of proposed...
Legal Alert: The season of giving – proposed regulations ease FATCA reporting burdens
Posted on Dec 21, 2018 in Legal Alerts
On December 13, 2018, proposed regulations (Proposed Regulations) were issued that reduce certain compliance obligations under Sections 1471-1474 (the Foreign Account Tax Compliance Act (FATCA)) of the Internal Revenue Code of 1986, as amended (Code) and Sections 1441-1446 of the Code. FATCA generally requires withholding 30% on certain US source payments made to foreign financial...
Legal Alert: And the BEAT goes on – proposed regulations clarify the application of the base-erosion and anti-abuse tax
Posted on Dec 20, 2018 in Legal Alerts
On December 13, 2018, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued proposed regulations under section 59A of the Internal Revenue Code of 1986, as amended, commonly referred to as the base-erosion and anti-abuse tax (BEAT). Read the full Legal Alert here.
Legal Alert: Real estate unlocked: Opportunity zones offer tax incentives to investors
Posted on Sep 7, 2018 in Legal Alerts, Uncategorized
As part of the Tax Cuts and Jobs Act of 2017, Congress added new rules to the Internal Revenue Code intended to promote investments in low-income communities designated as “qualified opportunity zones.” Deferral of tax on gains reinvested in Opportunity Funds and reduction or elimination of tax on such investments held for extended periods are the OZ Program’s carrots. Qualifying real...
LEGAL ALERT: IRS RELEASES NOTICE 2018-26 – RETROACTIVELY DISREGARDING CERTAIN ACCOUNTING METHOD CHANGES AND ENTITY CLASSIFICATION ELECTIONS
View the Eversheds Sutherland Legal Alert summarizing the treatment of certain accounting method changes and entity classification elections in Notice 2018-26 here.LEGAL ALERT: TRANSITION TAX – ENOUGH ABOUT HOW IT WORKS; HERE IS WHAT DOESN’T WORK
View the Eversheds Sutherland Legal Alert summarizing the new anti-avoidance rules and other technical guidance described in Notice 2018-26 with respect to which the Treasury and the IRS intend to issue regulations, effective as of the first taxable year of a foreign corporation to which section 965 applies, here.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.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.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.
Legal Alert: SEC Staff Provides Disclosure and Accounting Guidance in Response to Recent Tax Reform Legislation
Posted on Dec 27, 2017 in Legal Alerts, News
View the Eversheds Sutherland Legal Alert summarizing the guidance issued by the SEC Office of the Chief Accountant and the Division of Corporation Finance, in response to the recent tax reform legislation, regarding the information required to comply with ASC Topic 740, and the disclosure requirements under Item 2.06 of Form 8-K, which requires companies to reflect the impact of 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.
