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IRS Releases Notice on the Withholding Obligations of Non-publicly Traded Partnerships

On April 2, 2018, the IRS issued Notice 2018-29, which provides guidance related to withholding under Section 1446(f) with respect to the disposition of a partnership interest in a partnership that is not publicly traded. Read more here: Notice 2018-29

Resignation of Treasury Official Expected to Result in Guidance Delays

Treasury Deputy Assistant Secretary of Tax Policy Dana Trier stepped down from his position on February 23. Trier’s role focused on developing guidance on various aspects of the new tax reform law, including the partnership and international tax provisions. Practioners have expressed concern that his departure will result in delays in issuing regulations, which could result in...

Treasury Considering Treatment of Foreign Taxes Under Transition Tax

Under the new Tax Act, U.S. shareholders are charged a one-time tax on deferred foreign earnings of their foreign subsidiaries; these earnings and profits are measured as of November 2 if the amount is greater than on December 31.  Taxpayers have brought to Treasury’s attention that the use of the November 2 date can result in an overstatement of earnings because foreign taxes...

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...

IRS is Prioritizing Certain Guidance Related to Pass-through Entities

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...

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...

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.

With a Consensus Tax Bill, Christmas May Come Early for Republicans

An agreement between Senate and House Republicans on a tax bill was finalized Wednesday morning. According to lawmakers and reports from aides, Senate and House Republicans have agreed to provisions including the following: • Corporate tax rate will drop from 35% to 21%, to go in effect in 2018. • Individuals will be allowed to deduct up to $10,000 in state and local taxes, split...

Senate May Vote on Its Tax Reform Bill as Early as Thursday, but There Are Hurdles to Overcome

At least a half dozen Republican senators have shown concern about the Senate version of the Tax Cuts and Jobs Act, threatening the passage of the bill by the end of this year. The bill, passed out of the Senate Finance Committee on November 17, faces its next major hurdle from the Senate Budget Committee who will meet Tuesday, November 28, to add a revenue-raising measure allowing...

Senate Will Not Release Bill Until House Finishes Markup

The House Ways and Means Committee  continues the markup process that began on Monday.  No new amendments were agreed to in yesterday’s markup session but the state and local tax deduction and pass-through entities remain key issues in the debate concerning the legislation.  The House’s negotiation process has important implications for the Senate timeline as the Senate bill will not...

Rates Proposed by House’s Tax Bill

The tax bill released by the House Ways and Means Committee proposes significant changes to both individual and corporate rates. The corporate tax rate will be lowered from 35% to 20% while the rate on “pass-through” businesses will be lowered to 25%. On the individual side, tax rates will be consolidated into four brackets: 12%, 25%, 35% and 39.6%. Read more: Policy Highlights –...

Tax Reform Blueprint Expected to Include 25% Tax Rate for Pass-Through Entities

The GOP tax reform framework is expected to include a new 25% tax rate for “pass-through” businesses, so named because profits and losses transfer directly to the entity’s owners.  Income earned through pass-through businesses is currently taxed at individual income rates as high as 39.6%.  President Trump is scheduled to announce his tax reform plan, which will also...

Cohn Calls for Sub-23% Corporate Tax Rate

White House economic advisor Gary Cohn stated that the US must reduce the tax rate for corporations and pass-through entities below 23%.  He indicated such a rate is necessary to encourage domestic corporations to keep their profits in the US by competing with corporate tax rates offered by most member countries of the Organisation for Economic Co-operation and Development (OECD). ...

Ways and Means Committee Hears Testimony on Simplifying the Broken Tax Code

On Wednesday July 19th, the House Ways and Means Tax Policy Subcommittee, led by Subcommittee Chairman Peter Roskam, held a hearing on tax reform, titled “How Tax Reform Will Simplify Our Broken Tax Code and Help Individual Families.”  The hearing focused on individual tax reform.   Subcommittee Chairman Roskam, in his opening statement, touted the introduction of a postcard-sized ...

House Ways and Means Committee Plans to Permit Interest Deductions for Small Businesses

Rep. Peter Roskam, the Chairman of the Subcommittee on Tax Policy for the House Ways and Means Committee, has commented that they are “actively working” to exempt small businesses from the provision contemplated by the House Republican Blueprint that would deny deductions for net interest expense.  The Chairman noted that they are sensitive to those who have no access to capital except...


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