Eversheds Sutherland Tax Reform Law Blog
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Fiscal Year Taxpayers Reminded about Blended Corporate Tax Rate

Notice 2018-38, released April 16, reminds fiscal year taxpayers about the requirement to apply a blended tax rate under Section 15 of the Code to their taxable year that includes January 1, 2018.  The Tax Cuts & Jobs Act (the “TCJA”) changed the corporate tax rate, effective for taxable years beginning after December 31, 2017, in the middle of fiscal year taxpayers’ tax year....

Notice Confirms Business as Usual for Taxpayers with Advance Payments

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...

The OMB and Treasury Release Memo on OMB’s Oversight of Tax Regulations

The Office of Management of Budget (OMB) and the Department of Treasury recently issued a memo describing the framework for the OMB’s review of tax regulations. The memo provides that regulations will be subject to review if they 1) create a serious inconsistency or interfere with an action of another agency, 2) raise novel legal or policy issues, or  3) have an annual non-revenue...

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...

Transitional Guidance on Fines and Penalties Issued by IRS

Last week, the IRS issued Notice 2018-23 to assist government officials and taxpayers with complying with Sections 162(f) and 6050X of the Internal Revenue Code. The Tax Cuts and Jobs Act revised Section 162(f), which disallows deductions for fines and penalties, defined to exclude amounts paid as restitution or as reimbursement for investigations, or paid in suits where there is no...

Videocast: Implications of tax reform on income recognition

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...

IRS Releases Revenue Procedure Limiting Changes to Annual Accounting Periods

The IRS has restricted the ability of taxpayers to make certain changes in accounting periods, through the issuance of Revenue Procedure 2018-17. The revenue procedure modifies Revenue Procedure 2002-39 and Revenue Procedure 2006-45, which deal with approval for changes to annual accounting periods. The modification generally denies automatic approval for changes to tax years of...

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

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...

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,...

Legal Alert: The Tax Cuts and Jobs Act, Take Three: A Methods-Based Review of the Senate’s Initial Draft of Tax Reform Legislation

View the Eversheds Sutherland Legal Alert comparing the tax accounting and accounting method provisions of the initial Senate proposal that differ from the final legislative language passed by the Senate Finance Committee...

Legal Alert: The Tax Cuts and Jobs Act, Take Two: A Methods-Based Comparison of the Senate and House’s Tax Reform Plans

View the Eversheds Sutherland Legal Alert comparing accounting method issues in the House and Senate versions of H.R. 1 here.

Legal Alert: The Tax Cuts and Jobs Act, Take One: A Methods-Based Overview of the Initial Draft of the House Tax Bill

View the Eversheds Sutherland Legal Alert discussing accounting method issues in H.R. 1 here.

Senate Approves Budget, Easing Path Toward Tax Reform Legislation

The Senate approved a budget for 2018 with language permitting a simple majority vote on tax legislation through reconciliation. The budget language allows tax legislation to add up to $1.5 trillion dollars to the deficit over a decade, which the budget blueprint balances by assuming greater economic growth, cuts in spending and an accounting method that does not include Social...