Eversheds Sutherland Tax Reform Law Blog
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Section 168(k) Administrative Solutions Possible for QIP Error; Partnership Remedial Allocations

On August 16, the Senate Finance Committee sent a letter to Treasury clarifying the drafting error in the Tax Cuts and Jobs Act that failed to make qualified improvement property (QIP) eligible for 100% bonus depreciation under section 168(k). Ellen Martin, a tax policy adviser in the Treasury Office of Tax Legislative Counsel, commented that the letter was welcome but may not be...

New Rev. Proc. Provides that Citrus Replanting Costs Not Included in Automatic Accounting Method Changes

Released Tuesday, Rev. Proc. 2018-35 provides that the new automatic change procedures under Rev. Proc. 2018-31 do not apply section 263A to replanting costs for damaged or lost citrus plants. Section 263A generally requires taxpayers to include the costs of certain property produced or acquired for resale to be included in inventory costs. However, under section 263A(d)(2)(A) as...

Eighteen Guidance Priorities and New Projects Released in Second Quarter Update to Priority Guidance Plan

The second quarter update to the 2017-2018 Priority Guidance Plan was released by the Treasury and IRS this past Wednesday. It sets forth eighteen priorities for guidance on tax issues stemming from the Tax Act, including for new sections 965 and 163(j), and other international sections. The update also contains projects that are hoped to be completed through June 30, 2018. These...

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...

Joint Statement on Tax Reform Issued; BAT Abandoned

Today, House Speaker Paul Ryan, Senate Majority Leader Mitch McConnell, Treasury Secretary Steven Mnuchin, National Economic Council Director Gary Cohn, Senate Finance Committee Chairman Orrin Hatch (R-UT), and House Ways and Means Committee Chairman Kevin Brady (R-TX) issued a joint statement on tax reform that sets out a broad framework for moving forward on tax reform. Most notably,...

GOP to Release Tax Reform Framework

The top Republican tax negotiators are expected to unveil a broad set of agreed tax reform principles prior to the Congressional recess.  The anticipated framework is the result of ongoing deliberations between the “big six”:  Speaker of the House Paul Ryan, House Ways and Means Committee chairman Kevin Brady, Senate majority leader Mitch McConnell, Senate Finance Committee chairman...

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...