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....

IRS Releases Guidance on Section 163(j)

On April 2, 2018, the IRS issued Notice 2018-28, which provides guidance related to the interest deductibility limitation in Section 163(j). The Notice clarifies that Section 163(j) will treat taxpayers who file a consolidated return as a single taxpayer and that interest disallowed under the prior version of Section 163(j) may be carried forward and treated as business interest in...

EU Finance Ministers Debate the EU’s Response to the 2017 Tax Act

Finance ministers from key EU countries, including France, Germany and Italy, are questioning whether some of the provisions of the 2017 tax act are contrary to World Trade Organization (WTO) rules. The finance ministers are currently reviewing whether to file a complaint with the WTO out of concern that the tax act will spark a race to the bottom with respect to tax rates. EU finance...

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...

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

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...

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...

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...

Conference Committee Working to Resolve House and Senate Differences

Conference Committee negotiators in the House and Senate over the weekend did not reach a compromise on the different versions of the Tax Cuts and Jobs Act. The main issues include the timing of the 20% corporate rate cut and whether to allow deductions for state and local taxes. Currently, Congressional Republicans hope to finalize the bill by December 20th, and Kevin Brady, Chair of...

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 Tax Plan Will Include Repeal of the Affordable Care Act’s Individual Mandate

Finance Committee Chairman Orrin Hatch recently revised the Senate tax proposal to include a repeal of the Affordable Care Act’s individual mandate. Recent revisions also made many of the tax cuts for individuals temporary. Corporate tax cuts remain permanent. These changes were made so that the tax proposal would comply with the Senate’s Bryd Rule, which prevents legislation that...

Set Phasers to Stun: Corporate Tax Cuts May Be Delayed Under Phase-in Plan

An unnamed member of the House Ways and Means Committee stated Monday that the Committee is discussing a phase-in plan for the corporate tax-rate cut. In response, Kevin Brady, Chairman of the House Ways and Means Committee, said only that the Committee preferred an option with no phase-in. Both President Trump and Treasury Secretary Steve Mnuchin also expressed their preference for an...

Trump Administration Releases Tax Plan Outline

The Trump administration released an outline of their tax reform plan today, which sets out the key initiatives they will pursue. Their proposals include lowering the corporate tax rate to 15%, repealing the 3.8% Affordable Care Act tax, implementing a territorial tax system, and introducing a transition repatriation tax on “trillions of dollars held overseas.” Read more at: Cohn,...

Trump Announces Tax Cut Details Will Be Released Next Week

President Trump announced that his tax reform plan will be released next week. He promised a “massive tax cut” to businesses and individuals that could end up larger “than any tax cut ever.” He did not provide any insight into the contents of the plan. Read more at: Trump says he will release tax reform package next...

Former Trump Advisors Urge Piecemeal Approach to Tax Reform

Former Trump campaign advisors, Steve Forbes, Larry Kudlow, Arthur B. Laffer, and Stephen Moore, urged the Trump Administration and the Republican Party to not attempt to overhaul the entire tax code in one bill. Instead, they advocated first seeking to lower business rates, allow immediate expensing, impose a repatriation tax on overseas profits, and fund infrastructure projects. They...