Searching Content indexed under Tax Authorities by Martin Hamilton ordered by Published Date Descending.
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Proposed Regulations On Built-In Gains And Losses Under Section 382(h)
On September 10, 2019, the Internal Revenue Service ("IRS") and the U.S. Department of the Treasury (the "Treasury")
United States
25 Sep 2019
Final IRS Regulations Sync Section 956 With TCJA Participation Exemption – Limits "Deemed Dividends" For U.S. Corporate Shareholders Of CFCs
Implements 2018 Proposed Regulations, ending most limitations on investments in U.S. property, as well as pledges and guarantees by CFCs wholly-owned by U.S. corporations – also provides PTI guidance for CFC shareholders.
United States
14 Jun 2019
Section 1446(f) Proposed Regulations: Key Guidance On Partnership Interest Transfers By Non-U.S. Persons
On May 13, 2019, the IRS and Treasury Department published proposed regulations providing guidance on the rules imposing withholding and reporting requirements under the Code on dispositions of certain partnership interests ...
United States
6 Jun 2019
"Passthrough Deduction" Regulations Finalized
The passthrough deduction provides a maximum effective rate of 29.6%.
United States
20 Mar 2019
FATCA: Significant Relief In New Proposed Regulations
On December 13, 2018, the Internal Revenue Service (the "IRS") and the U.S. Department of the Treasury (the "Treasury") issued proposed regulations
United States
21 Dec 2018
Newly Proposed US Tax Regulations Open Possibility Of Full Credit Support From Foreign Subsidiaries
On October 31, 2018, the U.S. Treasury Department and the Internal Revenue Service (the "IRS") proposed new regulations under Section 956 of the Code.
United States
21 Nov 2018
IRS And Treasury Issue Proposed Opportunity Zone Regulations
The proposed regulations answer the most pressing questions with mostly taxpayer-friendly answers.
United States
23 Oct 2018
Treasury And IRS Issue Proposed "Pass-Through Deduction" Regulations
On August 8, 2018, the U.S. Department of the Treasury (the "Treasury") and the Internal Revenue Service (the "IRS") issued proposed regulations regarding the "pass-through deduction"
United States
31 Aug 2018
New Tax Law (H.R. 1): Key Highlights Related To Interest Bearing Debt
On Friday December 22, 2017, the President signed into law H.R.1, commonly referred to as the Tax Cuts and Jobs Act (TCJA).
United States
15 Jan 2018
House Of Representatives And Senate Conferees Reach Agreement On The Tax Cuts And Jobs Act (H.R. 1): Description Of The Conference Agreement And Differences From House And Senate Versions
On Friday, December 15, the U.S. House of Representative and Senate conferees reached agreement on the Tax Cuts and Jobs Act (H.R. 1), and released legislative text, an explanation...
United States
19 Dec 2017
An Update On The Status Of U.S. Tax Reform
The United States Congress has returned to Washington D.C. from the Thanksgiving holiday, and with their return, attention will return to U.S. tax reform legislation.
United States
30 Nov 2017
House Of Representatives Passes The Tax Cuts And Jobs Act (H.R. 1); Senate Finance Committee Approves Modified Version; Comparison Of The Bill Passed By The House And The Modified Senate Bill
Yesterday afternoon, the House of Representatives passed the Tax Cuts and Jobs Act (H.R. 1). The House bill is identical to the draft bill approved by the House Ways and Means Committee on November 10.
United States
21 Nov 2017
Tax Reform: Focus On The Sports Industry
The Senate Markup proposes to eliminate the tax exemption for professional sports leagues, regardless of size.
United States
14 Nov 2017
The Tax Cuts And Jobs Act
Today, the Republicans in the U.S. House of Representatives released their long-anticipated tax reform bill, entitled the "Tax Cuts and Jobs Act".
United States
3 Nov 2017
IRS Eliminates Signatures On Section 754 Elections, Offering Tax Regulatory Reform Preview (And Its Complexity?)
In a notice of proposed rulemaking issued on October 11, 2017, the U.S. Department of the Treasury and the IRS proposed an amendment to existing regulations under Section 754...
United States
18 Oct 2017
Tax Planning is Crucial to Achieve Potential Spin-Off Benefits
Today, the Wall Street Journal considers again, on its front page above the fold, the potential benefits of corporate spin-off transactions ...
United States
12 Oct 2017
IRS Resumes Issuing Transactional Spin-Off Rulings
On September 21, 2017, the Internal Revenue Service issued Revenue Procedure 2017-52, introducing an 18-month "pilot program" in respect of corporate "spin-off," "split-up" and "split-off" transactions.
United States
28 Sep 2017
Tax Court Rules That Extensions Of Variable Prepaid Forward Contracts Do Not Result In Taxable Exchanges
Last week, in McKelvey v. Commissioner¸ the U.S. Tax Court held that the extension of a typical VPFC did not give rise to a taxable exchange to the obligor because a VPFC is solely an obligation...
United States
2 May 2017
IRS Updates FATCA FAQs, Addresses January Temporary Regulations
Question 21 provides temporary relief from the new requirement of providing a foreign TIN for calendar year 2017 in the absence of the withholding agent's actual knowledge that the beneficial owner...
United States
26 Apr 2017
Final Regulations Released Regarding PFIC Ownership Determination and Annual Reporting Requirements
On December 27, 2016, the Treasury Department (Treasury) and Internal Revenue Service (IRS) released final regulations regarding the determination of ownership of a passive foreign investment company ("PFIC") and regarding certain exceptions to the annual PFIC reporting requirements (the "PFIC Regulations").
United States
21 Jan 2017
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