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Fiscal Year Taxpayers Reminded about Blended Corporate Tax Rate

Notice 2018-38, released April 16, reminds fiscal year taxpayers about the requirement to apply a blended tax rate under Section 15 of the Code to their taxable year that includes January 1, 2018.  The Tax Cuts & Jobs Act (the “TCJA”) changed the corporate tax rate, effective for taxable years beginning after December 31, 2017, in the middle of fiscal year taxpayers’ tax year....

Transitional Guidance on Fines and Penalties Issued by IRS

Last week, the IRS issued Notice 2018-23 to assist government officials and taxpayers with complying with Sections 162(f) and 6050X of the Internal Revenue Code. The Tax Cuts and Jobs Act revised Section 162(f), which disallows deductions for fines and penalties, defined to exclude amounts paid as restitution or as reimbursement for investigations, or paid in suits where there is no...

Resignation of Treasury Official Expected to Result in Guidance Delays

Treasury Deputy Assistant Secretary of Tax Policy Dana Trier stepped down from his position on February 23. Trier’s role focused on developing guidance on various aspects of the new tax reform law, including the partnership and international tax provisions. Practioners have expressed concern that his departure will result in delays in issuing regulations, which could result in...

Treasury Considering Treatment of Foreign Taxes Under Transition Tax

Under the new Tax Act, U.S. shareholders are charged a one-time tax on deferred foreign earnings of their foreign subsidiaries; these earnings and profits are measured as of November 2 if the amount is greater than on December 31.  Taxpayers have brought to Treasury’s attention that the use of the November 2 date can result in an overstatement of earnings because foreign taxes...

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...

“Permanent Tax Cuts of Americans Act” Introduced by the House

This past Monday, Republican House Representative Rodney Davis introduced H.R. 4886, to make the individual provisions of the newly enacted tax law permanent.  Under this bill, subtitles A and B of the tax law, which lower the individual tax rates, would be extended past their 2025 sunset dates with the goal to “provide future tax relief for individual taxpayers”. Read the Bill here:...

CRS Report Analyzes 2017 Federal Tax System In Anticipation of Tax Bill Changes

The Congressional Research Service (CRS) published Report 7-5700 on December 26, 2017, which provides an overview of the federal tax system as in effect through 2017. The report notes that the new tax bill, H.R. 1, will generate broad changes for individuals (personal exemptions; standard deduction) and businesses (different tax rate for pass-through business income; territorial tax...

Conference Committee Agreement Released for Tax Cuts & Jobs Act

House and Senate Republicans unveiled their collective tax bill with the Conference Report and Agreement early Friday night. The text follows the Senate bill, but resolves differences between the Senate and House bills, and makes modifications and clarifications throughout. Republicans are expected to vote this week. Conference Report and Bill Read more: GOP unveils sweeping tax...

With a Consensus Tax Bill, Christmas May Come Early for Republicans

An agreement between Senate and House Republicans on a tax bill was finalized Wednesday morning. According to lawmakers and reports from aides, Senate and House Republicans have agreed to provisions including the following: • Corporate tax rate will drop from 35% to 21%, to go in effect in 2018. • Individuals will be allowed to deduct up to $10,000 in state and local taxes, split...

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...

Senate May Vote on Its Tax Reform Bill as Early as Thursday, but There Are Hurdles to Overcome

At least a half dozen Republican senators have shown concern about the Senate version of the Tax Cuts and Jobs Act, threatening the passage of the bill by the end of this year. The bill, passed out of the Senate Finance Committee on November 17, faces its next major hurdle from the Senate Budget Committee who will meet Tuesday, November 28, to add a revenue-raising measure allowing...

White House Officials State Willingness to Sacrifice Health Care Provision for the Tax Reform Greater Good

The White House Budget Director, Mick Mulvaney, indicated that the Trump Administration is willing to strike the health care provision in the Senate’s proposed tax legislation repealing the requirement that everyone in the U.S. have health insurance or pay a fine. Striking this provision would leave the Senate $338 billion short of their revenue goal and would require Republican...

Orrin Hatch to introduce Senate tax reform bill amendments changing 401(k), IRA classifications

The Senate Finance Committee has released a full list of the proposed amendments to the Tax Cuts and Jobs Act currently under consideration. Chairman Senator Orrin Hatch will present several amendments to the Senate’s tax reform bill during the mark up. His proposal includes a provision allowing publicly traded companies to deduct up to 12.5% of dividends paid to shareholders from...

Senate Bill Anticipated Later This Week; House Begins Markup of Their Tax Reform Legislation

  The House Ways and Means Committee began marking up the GOP tax bill this afternoon, and the process is expected to continue until Thursday. The markup will start with opening statements and then amendments are expected to be introduced throughout the week by Chairman Kevin Brady.  With the floor open to Democrats, discussions and amendments are anticipated to focus on the...

President Trump Urges House Republicans to Adopt the Senate-Approved Budget to Speed Up Tax-Reform Process

President Trump and Vice President Mike Pence urged House Republicans on a conference call yesterday to speed up the tax reform process by adopting the Senate-approved budget without further amendments. The chairwoman of the House Budget Committee, Rep. Diane Black, as well as Speaker Paul Ryan also voiced their support for the passage of the Senate budget this week. The end of this...


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