Eversheds Sutherland Tax Reform Law Blog
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Legal Alert: IRS and Treasury Issue Final Regulations on Negative Adjustments under UNICAP

On November 19, 2018, the Internal Revenue Service (IRS) and the Treasury Department (Treasury) issued final regulations (T.D. 9843) that address taxpayers’ use of negative amounts in calculating additional costs for purposes of section 263A. Read the full legal alert...

Legal Alert: Allocation, Apportionment and Attribution, oh my – Proposed Foreign Tax Credit Regulations Provide Critical Guidance

On November 28, 2018, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued proposed regulations concerning foreign tax credit determinations and related issues (Proposed Regulations) to take into account changes to the Internal Revenue Code made by the Tax Cuts and Jobs Act (TCJA). The Proposed Regulations were highly anticipated because their...

Legal Alert: INXS? IRS Issues Proposed Regulations under Section 163(j)

On November 26, 2018, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued proposed regulations (Proposed Regulations) under section 163(j) of the Internal Revenue Code of 1986, as amended (the Code). The Tax Cuts and Jobs Act (the TCJA) amended “old” section 163(j) with an entirely new section 163(j) which operates to limit the ability of taxpayers...

Legal Alert: House Bill Proposes Tax Credit Extensions for Renewable Energy, Biodiesel and Alternative Fuels and other Energy Tax Provisions

On November 26, the House of Representatives released a tax bill (Extenders Bill) that, if enacted, would extend certain tax credits for the renewable energy and alternative fuels industries and would make other changes relevant to the energy sector. The Extenders Bill provisions include:  view full legal alert...

Eversheds Sutherland Seattle CPE Day – Navigating The Changing World of Tax – Day 2, November 7, 2018

Please view our presentations from day 2 of our Seattle CPE Day on federal and international tax planning. Hard Knock Life: The New Worldwide Territoriality and the Continuing Significance of the Foreign Tax Credit in the US – Speakers, Randy Buchanan and Robb Chase On to the Next One: The Increasing Importance of Destination in Tax Regimes – Speakers, Michele Borens, Randy...

Eversheds Sutherland Seattle CPE Day – Navigating The Changing World of Tax – Day 1, November 6, 2018

Please view our presentations from our Seattle CPE Day on federal and international tax planning. 99 Problems: Planning in a Time of Tax Uncertainty – Speakers, Robb Chase, Randy Buchanan, Mary Monahan and Stefanie Wood Empire State of Mind: International M&A Post Tax Reform – Speakers, Daniel Nicholas and Jed Rogers Can’t Knock the Hustle: The Implications of...

Eversheds Sutherland Year-End Tax Seminar – Navigating the Changing World of Tax, November 14, 2018, Philadelphia, PA

Please view our presentations from Eversheds Sutherland’s year-end tax seminar on federal and international tax planning. 99 Problems: Addressing Risk in a Time of Tax  Uncertainty – Speakers, Ellen McElroy, Karl Zeswitz and Michael Resnick Can’t Knock the Hustle: The Implications of International Reforms for Audit and Controversy – Speakers, Mary Monahan and Robb...

Legal Alert: Real estate unlocked: Opportunity zones offer tax incentives to investors

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...

Full Expensing Regulations Ready for Publication

On July 30, 2018, the Office of Management and Budget (“OMB”) waived its review of the Internal Revenue Service’s (“IRS”) proposed regulations that implement the full expensing provisions of the 2017 tax act. The full expensing provisions allow temporary 100% expensing for certain business assets. With the OMB review complete, the IRS may publish the proposed regulations in the Federal...

State Tax Reform Roundtables

The Tax Executives Institute’s (TEI) State and Local Tax Committee is holding a series of State Tax Reform Roundtables to enable SALT professionals to stay abreast of state tax developments associated with the Tax Cuts and Jobs Act, to engage with subject-matter experts, and to hear from peers regarding their “boots on the ground” knowledge and experience. This series of calls will...

Guidance on Section 199A May Halt Benefitting Firms

The Treasury Department may issue guidance on section 199A in response to workarounds taken by law and accounting firms. The new section 199A provides a 20% deduction for qualifying pass-through businesses. Since its enactment, offices have been broken down into separate businesses to take advantage of the deduction; future guidance may halt this technique. According to an official at...

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...

Congress to Begin Voting on the Tax Cuts and Jobs Act Today

With the Conference Agreement finalized, the Agreement must be approved by both the House and Senate, and once approved, it will head to President Trump for his signature. The House is expected to vote later today, and the Senate will vote soon afterwards, either today or tomorrow. Read more:  Tax Voting Starts...

House-Senate Conference Committee Meeting on Republican Tax Reform Bill Held Today

The House-Senate Conference Committee met today to discuss the previously passed Senate and House versions of the Tax Cuts and Jobs Act. During this meeting the Chief of Staff of the Joint Committee on Taxation, Thomas Barthold, provided a brief overview of the key differences in the tax bills and answered questions regarding the two bills in question. This is the only such meeting of...

All in a Late Night’s Work: Senate Passes Tax Bill

At approximately 2:00 a.m. on Saturday morning, the Senate passed its tax reform bill with a vote of 51-49. Changes to the bill, including some handwritten into the document, were made leading up to the final vote. The only Republican to vote against the bill was Senator Bob Corker who has continued concerns regarding the estimated $1+ trillion deficit over the next 10 years. Corker...


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