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Chamber of Commerce Provides Feedback on Notice 2018-07

The U.S. Chamber of Commerce recently released recommendations for further guidance in response to Notice 2018-07, which provides guidance related to section 965 (the transition tax on deferred foreign earnings). The recommendations include excluding short-term loans from foreign affiliates to a U.S. parent from aggregate foreign cash if they have previously triggered a taxable...

IRS is Prioritizing Certain Guidance Related to Pass-through Entities

As the IRS continues to work on guidance for the new tax legislation (formerly known as the Tax Cuts and Jobs Act), the agency is prioritizing certain complex provisions that relate to pass-through entities. In comments to the New York State Bar Association, Clifford Warren, special counsel to the IRS associate chief counsel, identified section 199A (qualified pass-through business...

IRS Modifies Notice 1036 Withholding Tables Incorporating Changes to the Individual Tax Rates

The IRS recently released an updated version of Notice 1036 (includes income tax withholding tables for employers) which integrates the changes made by the recently passed tax legislation. The notice states that employers must implement the withholding tables by February 15, 2018. The IRS anticipates updating its online withholding calculator by the end of February. Read more: New 2018...

Speaker Ryan Foresees only Technical Corrections to the Tax Reform Bill, Rather Than Major Changes

In an interview with C-SPAN, House Speaker Paul Ryan stated that the bill previously known as the Tax Cuts and Jobs Act would require some technical corrections, such as in the area of international taxation, though he did not offer further details. He anticipates that any corrections to the bill would be small changes. House Ways and Means Committee Chair Keven Brady has also stated...

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...

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...

Conference Committee to Release Tax Bill and Report Tonight but Passage not Guaranteed

The conference committee has announced they will approved a conference report on the final version of the Tax Cuts and Jobs Act. The report and the bill text will be released tonight. The Republicans can only afford to lose two votes in the Senate in order to pass the final version.  Senator Marco Rubio announced that he will not support the tax bill unless Senate Republicans are able...

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...

Brady Indicates That Tax Legislation Will Include Repeal of Individual Mandate

The Senate voted to go to conference in order to reconcile their tax bill with the House Tax bill today. However, there are many differences that need to be worked out between the two bills. Key differences include the repeal of the alternative minimum tax, the implementation timing of the corporate tax rate reduction, and the repeal of the individual mandate. The repeal of the...

House Sends Tax Cuts and Jobs Act to Conference Committee

The House voted Monday to send the Tax Cuts and Jobs Act to conference committee to resolve the differences between the House and Senate versions of the bill. The committee has 14 House total members, 9 Republican and 5 Democratic. The Republican members are: Keven Brady (the Chair of the House Ways and Means Committee), Ron Bishop, Diane Black, Kristi Noem, Devin Nunes, Peter Roskam,...

Increased Support Among Senate Republicans For Tax Bill But Some Opposition Remains

The Senate voted today on party lines to proceed with floor debate on the tax bill. Recently, there has been increased support for the tax legislation among Senate Republicans. Senators James Lankford and Jerry Moran, both former holdouts, indicated that they would support the legislation. Senators Ron Johnson and Bob Corker, vocal critics of the bill, both voted in favor of the bill...

Senate Budget Committee Passes the Tax Cuts and Jobs Act

The Senate Budget Committee has passed the Tax Cuts and Jobs Act on a 12-11 vote. This procedural hurdle was necessary for the bill to be considered on the floor of the Senate. Read more: Senate Budget Committee Advances GOP Tax Bill

Senate Tax Bill Differs from House Bill in Treatment of Multinationals

The Senate recently released the legislative text of their version of the tax bill. The bill defers in several key respects from the House bill in its treatment of the income of multinational companies, particularly in the way that it addresses global intangible low-taxed income, foreign derived intangible income, and base erosion. The Senate vote could occur as early as November 30th....

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...

Senate Will Not Release Bill Until House Finishes Markup

The House Ways and Means Committee  continues the markup process that began on Monday.  No new amendments were agreed to in yesterday’s markup session but the state and local tax deduction and pass-through entities remain key issues in the debate concerning the legislation.  The House’s negotiation process has important implications for the Senate timeline as the Senate bill will not...


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