Eversheds Sutherland Tax Reform Law Blog
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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 significant cash assets, which cause a corresponding amount of earnings to be taxed at almost double the rate.  Recent IRS guidance states that derivatives, routinely used by banks and broker-dealers, will be...
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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 system) alike. The report also explains and provides analysis regarding the 2017 individual income tax, corporate income tax and other taxes, including those on insurance, retirement and estates. Additionally,...
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California Proposes Bill to Permit Donations Instead of State Taxes as Challenge to New Federal Tax Bill

The California legislature has introduced a bill that permits residents to donate to a state “public purpose” fund and receive a dollar-for-dollar tax credit on their returns. This donation is intended to be deductible for federal tax purposes as a means of circumventing the new $10,000 cap on state/local tax deductions included in the recently passed tax bill. White House economic adviser Gary Cohn said the federal government might try to block attempts to circumvent the cap.   Read more: California bill takes aim at new federal tax deduction...
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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.
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New York Challenges Federal Government’s Tax Reform Bill as Unconstitutional Double Taxation

In his recent speech before the state legislature, New York Governor Andrew M. Cuomo stated that the reduction in the state and local tax deduction reflected in the new tax reform bill is unconstitutional double taxation. The governor further indicated that New York would challenge the provision. Cuomo also said that the state will undergo its own tax revision process, shifting away from its reliance on income taxes. Read more: In State of State speech, Cuomo vows to sue federal government over tax bill...
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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 also covers topics like the treatment of related-party transactions and hedging transactions, as well as the effective dates for the transition tax. Read more:  Notice...
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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.
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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.
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Legal Alert: Section 162(q) Raises Questions about Deductibility of Employment Settlement

View the Eversheds Sutherland Legal Alert discussing the impact of the Final Tax Reform Bill on the settlement of employment-related claims here.
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Legal Alert: SEC Staff Provides Disclosure and Accounting Guidance in Response to Recent Tax Reform Legislation

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 law changes in the quarter in which the law is enacted...
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President Trump Signs Tax Bill into Law

President Trump signed the tax bill passed by the House and Senate this morning. The bill will be generally effective beginning January 1, 2018. Read the bill text here.  Read more about the bill’s passage here.
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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.
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Title: Tax Bill Passes in House

House Republicans voted to pass the Senate’s revised version of the Tax Cuts and Jobs Acts today. Read More: House sends sweeping GOP tax bill to Trump’s desk
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Tax Bill Passes in Senate Wednesday Morning, House Expected to Vote (Again) Later Today

Senate Republicans voted to pass a revised version of the Tax Cuts and Jobs Acts early Wednesday morning. The House voted yesterday in favor of the legislation, however several minor provisions of the bill did not comply with Senate rules and had to be removed. The House is expected to vote on the revised version of the bill sometime today. Read More:  Senate passes sweeping GOP tax bill, but House to vote again
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House Passes Revised Bill; Senate to Vote as Early as Tonight

The House has passed the Tax Cuts and Jobs Act, as revised by the Conference Committee, along party lines. The bill will now go to the Senate, who may vote as early as this evening. Should the bill pass both houses, it will be sent to President Trump to sign into law. Read more:  House Passes Final Tax Bill; Senate Votes Next on Republican Plan
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