January 15, 2021
Treasury and IRS Issue Final Regulations on Simplified Tax Accounting Rules for Small Businesses Under the TCJA
Treasury and IRS recently issued final regulations (TD 9942), offering guidance under the various regulations to adopt the simplified tax accounting rules for small businesses under the Tax Cuts and Jobs Act (TCJA). The
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January 12, 2021
Treasury and IRS Issue Final Income Recognition Rules Under TCJA
Final regulations (TD 9941) implementing the income recognition rules enacted under the Tax Cuts and Jobs Act (TCJA) under Sec. 451(b) and (c) were recently released. The final regulations for both provisions include many
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November 13, 2020
Treasury and IRS Will Respect State Pass-Through Entity Workaround Laws Aimed at Circumventing TCJA’s SALT Deduction Cap
Partnerships and S corporations based in a state and local jurisdiction that imposes a mandatory or elective income tax at the entity level are allowed to fully deduct state and local income taxes
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October 08, 2020
Treasury and IRS Release Final Regulations on Gain or Loss of Foreign Persons From the Sale or Exchange of Certain Partnership Interests
Final regulations released by Treasury and IRS offer guidance for foreign persons that recognize gain or loss from the sale or exchange of an interest in a partnership that is engaged in a
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September 11, 2020
Final and Proposed Regulations on Section 163(j) Business Interest Expense Limitation Address Cost Recovery Issues
On July 28, 2020, the Treasury Department released a package of final regulations (TD 9905) (Final Regulations) and proposed regulations (REG-107911-18) (2020 Proposed Regulations) that provide guidance on the business interest expense limitation under Sec. 163(j).
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August 26, 2020
Final Regulations on Section 163(j) Business Interest Expense Deduction Limitation Provide Narrower Definition of Interest
On July 28, 2020, the Treasury Department released a package of final regulations (TD 9905) (Final Regulations) and proposed regulations (REG-107911-18) (2020 Proposed Regulations) that provide guidance on the business interest expense limitation under Internal Revenue
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August 14, 2020
Treasury and IRS Release Long-Awaited Guidance on Carried Interest Rule in Section 1061
On July 31, 2020, Treasury and IRS released proposed regulations regarding Sec. 1061’s carried interest rule, which was enacted as part of the Tax Cuts and Jobs Act (TCJA). Targeting incentive allocations made to
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July 24, 2020
IRS Issues Guidance on GILTI High-Tax Exclusion
Treasury and IRS issued final regulations (T.D. 9902) allowing taxpayers to exclude certain high-taxed income of a controlled foreign corporation (CFC) from their global intangible low-taxed income (GILTI) computation on an elective basis.
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July 22, 2020
Final Regulations Related to GILTI Deduction Provide Potential Benefits for Individuals
IRS and Treasury released final regulations (T.D. 9901) under Sec. 250 of the Internal Revenue Code (Code). The final regulations provide potential benefits for individuals subject to GILTI. Individuals making a Sec. 962 election are
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July 21, 2020
Final Regulations Under Section 250 Offer Additional Clarity for Determining the Foreign-Derived Intangible Income Deduction
IRS and Treasury have released final regulations under Sec. 250 of the Internal Revenue Code (Code). The final regulations adopt the basic structure and approach of the proposed regulations but diverge in several notable
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June 26, 2020
Proposed Regulations Address Elimination of the Deduction of Qualified Transportation Fringe Benefits Under the Tax Cuts and Jobs Act
Treasury and IRS issued proposed regulations implementing the elimination of the deduction by employers of qualified transportation fringe (QTF) expenses under the Tax Cuts and Jobs Act (TCJA) for tax years beginning after 2017.
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May 08, 2020
Taxpayers Face Uncertainty on State Treatment of Interest Expense Deduction for Affiliated Groups
With the second filing season underway after the enactment of the 2017 Tax Cuts and Jobs Act (TCJA) many states have yet to provide guidance on how the TCJA’s business interest expense
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March 02, 2020
New Guidance on Scaled-Back Deduction for Meals and Entertainment Under the TCJA
Proposed regulations explain how to determine whether an activity will be disallowed as an entertainment expense. The proposed rules also address the limitation on the deduction for food and beverages provided at or
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January 29, 2020
Final Regulations Make Key Changes, Add Flexibility and Resolve Some Uncertainties Regarding Qualified Opportunity Zones
Treasury and IRS adopted final regulations related to the Qualified Opportunity Zone (QOZ) program included within the Tax Cuts and Jobs Act (TCJA). The TCJA provided for the qualification of certain low-income census
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January 15, 2020
2019 Year-End Tax Act Provides Retroactive Tax Relief for Tax-Exempt Organizations and Donors
Year-end government funding legislation (H.R. 1865) enacted on December 20, 2019, includes significant tax provisions of interest to tax-exempt organizations. The tax-exempt parking tax was retroactively repealed, entitling tax-exempt organizations who paid the tax to
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December 22, 2019
Proposed Regulations on SALT Cap Workarounds Maintain Focus on State-Created Charities, But Remain Silent on Pass-Through Planning
Treasury and IRS released proposed rules incorporating earlier guidance on the treatment of payments made to charitable organizations in return for tax credits as payments of state or local taxes for federal income
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December 04, 2019
Taxpayers Benefiting from Temporarily Raised Estate and Gift Tax Exclusion Amount Will Not Be Adversely Impacted in Future Years
Individuals taking advantage of the increased gift and estate tax exclusion amounts in effect from 2018 to 2025 enacted under the Tax Cuts and Jobs Act (TCJA) will not be adversely impacted after 2025 when the
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November 08, 2019
IRS Form Instructions Would Reduce the Section 199A Deduction for Charitable Contributions Made by a Business
Draft instructions to both the 2019 Form 8995 and the 2019 Form 8995-A provide additional guidance on computing QBI beyond the scope of guidance in the final regulations
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September 27, 2019
The States’ Evolving Responses to Tax Reform Present Opportunities and Challenges to Business Taxpayers
The states’ responses to the sweeping changes under the Tax Cuts and Jobs Act (TCJA) are as varied as their own unique tax codes.
Determining a state’s approach to TCJA
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July 11, 2019
Final GILTI Regulations Include Beneficial Change for Certain Partners in Partnerships That Own CFCs
Under final regulations, GILTI inclusions are not determined at the partnership level—domestic partnerships are instead treated as an aggregation of their partners for purposes of GILTI.
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May 30, 2019
New Excise Tax on Executive Compensation May Entrap For-Profit Entities
New Sec. 4960 imposes a 21% excise tax on compensation in excess of $1 million, or any excess parachute payment paid, to a covered employee of a tax-exempt organization.
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April 24, 2019
Treasury Issues Additional Proposed Regulations on Qualified Opportunity Zones
On April 17, 2019, Treasury and IRS released a second set of proposed regulations (the New Proposed Regulations) with respect to Qualified Opportunity Zones (QOZs). The New Proposed Regulations clarify a number of requirements for
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February 14, 2019
Blue Book Sheds Light on New NOL Deduction and Carryover Losses
The Tax Cuts and Jobs Act (TCJA) did not explain how a taxpayer with both net operating loss (NOL) carryforwards from taxable years before and after the TCJA effective date should apply the
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December 26, 2018
IRS Issues Interim Guidance for Tax-Exempt Employers on Parking Fringe Expenses
IRS has issued two notices to address the tax treatment of qualified transportation fringe benefits, as modified by the Tax Cuts and Jobs Act (TCJA).
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December 26, 2018
IRS Issues Interim Guidance for Employers on Parking Fringe Expenses
IRS has issued a notice to address the tax treatment of qualified transportation fringe benefits, as modified by the Tax Cuts and Jobs Act (TCJA).
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December 20, 2018
Qualified Opportunity Zones – Regulatory Guidance Clears the Path for Investors
The Tax Cuts and Jobs Act (TCJA) codified new tax incentives aimed at attracting investment into low-income communities and certain contiguous areas certified by Treasury as qualified opportunity zones (QOZs). Taxpayers that
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September 13, 2018
Tax Reform - IRS Issues Guidance on New UBTI Rules for Separate Trades or Businesses
IRS has issued Notice 2018-67 (the Notice) to provide guidance on the calculation of unrelated business taxable income (UBTI) for tax-exempt organizations following tax reform. The Tax Cuts and Jobs Act (TCJA) changed
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August 21, 2018
The New Foreign-Derived Intangible Income (FDII) Deduction
The Tax Cuts and Jobs Act (TCJA) presented a significant change to the international tax regime. Among the changes was the introduction of a new special deduction for domestic C corporations for Foreign-Derived
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August 08, 2018
Guidance Released on New 20% Pass-Through Deduction; Includes Aggregation Election
IRS and Treasury have released the first set of proposed regulations related to the new 20% deduction for qualified business income under Sec. 199A, enacted as part of the Tax Cuts and Jobs Act
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August 02, 2018
Treasury Issues Regulations on Transition Tax on Foreign Earnings
Treasury and IRS have issued proposed regulations related to the new mandatory deemed repatriation under Sec. 965 (the Transition Tax). The proposed rules include additional guidance and definitions that are useful for many taxpayers.
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July 30, 2018
IRS Clarifies Effect of Suspended Miscellaneous Itemized Deductions on Trusts and Estates
IRS has announced in Notice 2018-61 (the Notice) that it will issue regulations to clarify that trusts and estates will be allowed to take deductions for expenses that are unique to trust and
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July 24, 2018
The New Global Intangible Low-Taxed Income (GILTI) Regime
The Tax Cuts and Jobs Act (TCJA) introduced an entirely new taxing regime under U.S. federal tax law, known as the global intangible low-taxed income (GILTI) regime.
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May 16, 2018
Tax Reform – Blended Rate for Fiscal Year Taxpayers (Regular and AMT)
The Tax Cuts and Jobs Act (TCJA) replaced the previous graduated corporate tax rate structure (top rate of 35%) with a flat tax rate (21%) and repealed the alternative minimum tax (AMT)for corporations for
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April 09, 2018
Tax Reform - Qualified Opportunity Zones: Opportunity to Defer and Potentially Eliminate Tax on Gains
The Tax Cuts and Jobs Act (the TCJA) provides a new tax benefit starting on December 22, 2017 that is aimed at attracting investments in low-income communities and some surrounding census tracts certified by
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March 22, 2018
Accounting Methods Update: Changes to Tax Rules Affecting Businesses and Individuals
Click here to read about some of the legislative changes made by the Act and the impacts of the new provisions as they relate to accounting method considerations.
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February 09, 2018
Tax Reform Act of 2017 – Highlights of the Key Items
The following charts set forth some of the provisions in the Tax Reform Act of 2017 and offer insights from Andersen’s technical experts. The charts highlight only some of the key issues
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January 17, 2018
Tax Reform – Impact on Financial Reporting
Click here for information regarding some of the accounting for income tax considerations related to key provisions in the final tax reform legislation.
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January 04, 2018
Updated: The Impact of the New Tax Reform Legislation on Business Real Estate and Partnerships
Click here to read more about the impact of the new tax reform legislation on business real estate and partnerships.
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December 22, 2017
Updated: Tax Reform – Effects on Inbound Foreign Investment
With the passage of the Tax Cuts and Jobs Act (the Act) into law, it is appropriate to now attempt to evaluate the effects of the reform on the tax planning for inbound
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December 20, 2017
Tax Reform – Year-End Planning for Individuals and Trusts
The House and Senate have voted to approve the compromise tax reform bill and final tax reform legislation is headed to President Donald Trump for his signature.
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December 02, 2017
Senate Approves Tax Bill in Race to Enact Tax Reform by Year End
Senate Republicans voted early Saturday morning to approve the Senate’s version of the Tax Cuts and Jobs Act with a vote of 51-49 on a party line vote. Bob Corker was
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December 08, 2017
Tax Reform – Effects on Inbound Foreign Investment
Click here to view information regarding the effects on inbound foreign investment.
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November 30, 2017
House and Senate Tax Reform Proposals – Highlights of the Key Issues
The following charts set forth some of the provisions in the Tax Cuts and Jobs Act. The House version of the Tax Cuts and Jobs Act was approved by the House
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November 17, 2017
House Passes and Senate Finance Committee Advances Landmark Tax Reform Legislation
The House passed its version of the Tax Cuts and Jobs Act on November 16, 2017, along a mostly party-line vote of 227-205, with 13 Republicans voting no along with every Democrat. The Senate Finance Committee
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November 03, 2017
House Releases Draft Tax Reform Legislation to Overhaul Tax Code
On November 2, 2017, the House Committee on Ways and Means Chairman Kevin Brady (R-Texas) released the latest piece in the tax reform puzzle—a draft bill to overhaul the tax code. The Tax
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October 26, 2017
House Approves Senate Budget, Puts Tax Reform on Fast Track
On October 26, 2017, the House of Representatives approved the budget resolution previously passed by the Senate less than a week before. The House’s slim party-line vote (216-212) on a compromise budget eliminates
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October 20, 2017
Senate Approves Budget Setting Stage for Release of Tax Reform Details
The Senate approved its fiscal year 2018 budget resolution the evening of October 19, 2017 on a largely party-line vote of 51-49, with a vote against from Republican Senator Rand Paul (R-KY). The House of Representatives
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September 28, 2017
Republicans Release Unified Framework for Tax Reform, Open Door to Tax Increase on Wealthy
On September 27, 2017, The Trump Administration, House Committee on Ways and Means, and Senate Finance Committee released a nine-page Unified Framework for Fixing Our Broken Tax Code (Unified Framework) that specifies a proposed tax
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August 18, 2017
Republicans Pitch Tax Reform to the American People
Former President Ronald Reagan signed the Tax Reform Act of 1986 on August 16, 1986. Now, over three decades later, Ways and Means Chairman Kevin Brady made his pitch for tax reform from Reagan’s
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August 01, 2017
August Has Arrived, But Tax Reform Details Remain Scarce
After months of closed-door meetings on tax reform, the Big Six—a working group of Republican leaders that includes Secretary of Treasury Steven Mnuchin, National Economic Council Director Gary Cohn, Speaker of
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November 30, 2017
Alternative Investment Funds: Tax Proposals Impact But Do Not Dampen Their Use: An Update
Click here to view additional information regarding how investment funds are affected by each bill.
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November 30, 2017
Tax Reform Planning for Multinational Corporations
Click here to read more about how Andersen can help multinational corporations prepare for tax reform.
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