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Treasury Confirms Issuance of Transition Tax Regulations by the End of the Year

Brenda Zendt, special adviser to the Treasury Office of International Tax Counsel, corroborated a prior report that the Treasury Department intends to issue final Section 965 regulations by the end of 2018. Treasury deputy assistant secretary for international tax affairs, Chip Harter, previously commented on the deadline while discussing Treasury’s goal to issue proposed regulations,...

IRS Provides Interim Guidance on Expenses for Business Meals

The Treasury Department and IRS issued Notice 2018-76, offering interim guidance under section 274 of the Code. The guidance provides that taxpayers may treat certain business meal expenses as non-entertainment and may continue to deduct 50 percent of food and beverage expenses associated with operating their business or trade, so long as the expenses are not extravagant and the...

House Approves Three New Tax Bills

On September 27, 2018, the House approved two bills that are part of a second package of tax law changes advanced by House Republicans (“Tax Reform 2.0”). The first bill would create universal savings accounts, expand the utility of section 529 education savings plans, and make the offering of employee retirement plans more accessible for small businesses. The second bill would provide...

Tax Reform 2.0 Will Likely Not Be Passed By Congress Before Midterms

House Ways and Means Committee Chair Kevin Brady recently stated that the three tax bills that together comprise the new tax reform package will likely not get through the Senate before midterm elections. The House Ways and Means Committee previously passed the bills through committee. The House is expected to vote the legislation later this month. Read More: Top House tax writer Kevin...

IRS Releases Draft Forms for Transition Tax and BEAT Reporting

The IRS released draft forms for reporting a taxpayer’s section 965 transition tax and section 59A base erosion and anti-abuse tax liabilities. The forms, titled Form 965 (“Inclusion of Deferred Foreign Income Upon Transition to Participation Exemption System”) and Form 8991 (“Tax on Base Erosion Payments of Taxpayers With Substantial Gross Receipts”), respectively, can be found on the...

Draft of Tax Reform 2.0 Introduced in Congress

House of Ways and Means Committee Chair Kevin Brady recently highlighted the introduction of three new tax bills that together comprise the new tax reform package. The drafts of new tax legislation deal primarily with individuals, retirement savings, and small businesses. H.R. 6760, the Protecting Family and Small Business Tax Cuts Act of 2018, would extend the 20 percent deduction on...

IRS Releases Proposed Regulations Addressing Purported Charitable Contributions in Exchange for State and Local Tax Credits

On August 23, 2018, the IRS released proposed regulations under section 170, which allows deductions for certain charitable contributions. The regulations are in response to plans by some states to circumvent the $10,000 deduction limitation for state and local taxes imposed by the Tax Cuts and Jobs Act by offering tax credits for contributions to certain government programs. The...

Presentation by Proposed Section 168(k) Regulations Team Provides Insight Into Significant Policy Decisions

On August 21, 2018, the Federal Bar Association hosted at Eversheds Sutherland’s Washington, D.C. office, a panel discussion with the team of IRS and Treasury professionals who drafted the proposed regulations for section 168(k).  Kathy Reed and Betsy Binder of the IRS Office of Chief Counsel were joined by Ellen Martin of the Department of the Treasury, as well as Barbara Young, Vice...

IRS Releases Interim Guidance for Unrelated Business Taxable Income

The IRS released Notice 2018-67, which provides interim guidance addressing section 512(a)(6). Section 512(a)(6), added by the Tax Cuts and Jobs Act, requires a taxpayer to calculate its unrelated business taxable income separately for each unrelated trade or business in which the taxpayer is engaged. In determining whether a taxpayer has more than one trade or business, the Notice...

Federal Register Publishes Proposed Passthrough Deduction Regulations

On August 16, 2018, the Federal Register published the Treasury and the IRS’s proposed passthrough deduction regulations. The regulations provide guidance on section 199A, which grants up to a 20% deduction for certain business income with respect to individuals and passthrough entities. The publication in the Federal Register begins the comment period for the proposed regulations, and...

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.


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