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Federal Register Publishes Proposed Transition Tax Regulations

On August 9, 2018, the Federal Register published the Treasury and the IRS’s proposed transition tax regulations. While the IRS had made an initial draft of the proposed regulations available for review, publication in the Federal Register begins the comment period for the proposed regulations. Comments on the proposed regulations must be received by October 9, 2018. Read More: Federal...

Proposed Pass-Through Deduction Regulations Released

The IRS has released proposed regulations on section 199A, a provision added by the Tax Cuts and Jobs Act that provides a deduction for certain qualified business income with respect to individuals and pass-through entities. Read more: IRS issues proposed regulations on new 20 percent deduction for passthrough businesses;...

AICPA and CIMA US Tax Reform Conference 2018

Eversheds Sutherland is the proud lead sponsor of the Association of International Certified Professional Accountants (AICPA) and the Chartered Institute of Management Accountants (CIMA) US Tax Reform Conference 2018 on September 17, 2018, at the Jumeirah Carlton Tower Hotel in London, United Kingdom. The US and International Eversheds Sutherland Tax team will be chairing the event and...

Regulations on Bonus Depreciation Are Mostly as Expected

The proposed regulations addressing section 168(k) bonus depreciation largely conform to expectations, however there were a few unanticipated elements. In her recent comments to the press, Ellen McElroy of Eversheds Sutherland (US) LLP highlighted the IRS’ failure to address the drafting error that left qualified improvement property ineligible for bonus depreciation. McElroy also...

Proposed Full Expensing Regulations Released

The IRS has released regulations on the full expensing provisions under section 168(k), as amended by the Tax Cuts and Jobs Act.  That section allows businesses to fully expense certain business assets. Read more: REG-104397-18.

Full Expensing Regulations Ready for Publication

On July 30, 2018, the Office of Management and Budget (“OMB”) waived its review of the Internal Revenue Service’s (“IRS”) proposed regulations that implement the full expensing provisions of the 2017 tax act. The full expensing provisions allow temporary 100% expensing for certain business assets. With the OMB review complete, the IRS may publish the proposed regulations in the Federal...

OMB’s Review of 199A Regulations to Be Completed in Ten days

Last week, the Office of Management and Budget’s Office of Information and Regulatory Affairs (OIRA) received draft proposed computational section 199A regulations from Treasury. OIRA’s expedited deadline for this review is ten business days after receipt of all necessary information, subject to extension as agreed with Treasury. Guidance sent to OIRA is generally subject to a 45-day...

Nunes’s Proposed Legislation Would Consider Inflation in Determining Capital Gains Tax

Devin Nunes, a Republican member of the House Ways and Means Committee, has introduced legislation to index capital gains for inflation. Under Nunes’s legislation, the tax basis of a capital asset for purposes of calculating capital gains would be adjusted for inflation. Republican Senator Ted Cruz has introduced similar legislation in the Senate, and Congressional Republicans are...

The Tax Cuts and Jobs Act Could Impact Intangible Valuation

Thomas Amendolari, a senior economist at the Treasury Department, recently stated that many of the fundamental aspects of determining the discount rate, for purposes of valuing intangible transfers under the section 482 regulations, may be affected by the 2017 TCJA. While the economic effects of the TCJA may increase discount rates, Amendolari noted that it is not yet certain and...

David Kautter Announces that Guidance on the Section 199A Pass-through Deduction will be Released in Weeks

On July 17, 2018, David Kautter, the acting Commissioner of the Internal Revenue Service (“IRS”), announced that the Treasury Department is currently reviewing guidance under section 199A and anticipates the guidance to be released within weeks. Kautter further stated that the IRS is treating the section 199A deduction, the section 59A base erosion and anti-abuse tax (“BEAT”), and the...

Brady Announces that the Outline of Phase 2 of Tax Reform will be Released Next Week

Kevin Brady, Chairman of the House Ways and Means Committee, announced on July 18, 2018 that an outline of the “phase 2” tax reform legislation will be released during the week of July 23rd. Brady also stated that the phase 2 legislation will not include any technical corrections or refinements to the 2017 tax act and that the focus of the legislation will be to make permanent the...

The Office of Management and Budget Received Draft Transition Tax Regulations

On July 13, the Office of Management and Budget’s Office of Information and Regulatory Affairs (OIRA) acknowledged receipt on its website of proposed rules under section 965.  The rules are currently under review, but OIRA has indicated that they are not economically significant, and therefore the normal 45-day review timeline (subject to extension) applies. Read more: Transition Tax...

Vote on Technical Corrections Bill Not Expected Until After Midterm Elections

While House Republicans are in the process of drafting a technical corrections bill, House Republican leaders do not expect vote a on the bill until after the midterm elections in November. The technical corrections bill would be separate from the “phase 2” tax legislation that would make the individual tax cuts implemented by the 2017 tax act permanent. Kevin Brady, chairman of the...

European Commission Discussing Implementation of the TCJA with U.S. Officials

According to Valdis Dombrovskis, a European Commissioner, the European Commission is speaking with U.S. officials about the Commission’s concerns with the 2017 tax act. European finance ministers have claimed that some provisions of the act violate international norms and double taxation treaties, especially the Base Erosion and Anti-Abuse Tax (or BEAT), which some commentators claim...

The White House Office of Management and Budget Has Not Yet Reviewed any New Tax Law Rules

Based on a new arrangement between the White House Office of Management and Budget (OMB) and Treasury, regulations and other guidance that have policy or economic significance will undergo a compliance review by the OMB. A senior administration official recently stated that Treasury and IRS have not yet sent any new tax regulations or guidance to the OMB for review, despite officials...


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