Eversheds Sutherland Tax Reform Law Blog
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Proposed Regulations and Guidance on Sections 199A and 163(j) Will Draw on Existing Regulations

The IRS is incorporating relevant existing regulations in drafting the proposed regulations for sections 199A and guidance for section 163(j). However, as noted by Holly Porter, acting IRS associate chief counsel, there are limitations to the degree to which application of these two sections can rely on regulations already existing under other sections due to the differences in nature...

Treasury Secretary Mnuchin Says Pass-through Rate Cut Not for the Wealthy

On May 18, Treasury Secretary Mnuchin attempted to assuage fears that the Trump tax plan will favor the wealthy. Trump’s tax reform outline proposes a 15% tax rate on business income, including income of individuals derived from pass-through entities, which is currently subject to a top marginal rate of 39.6%. While the outline includes few details, some commentators have expressed...