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A Practical Roadmap Through Section 199A

In 199A, Tax Reform by Jason Freeman3 Comments

Perhaps no other provision of the Tax Cuts and Jobs Act of 2017 has given rise to more speculation, debate, and consternation than new Section 199A. The complex maze that is Section 199A introduces a set of rules and formulas that determine when a taxpayer qualifies to deduct 20 percent of certain income from “pass-through” trades or businesses. The provision, …

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New Changes Are Coming to Partnership Withholding

In International Tax, Offshore Tax, Partnership Tax, Tax Reform by Vu LeLeave a Comment

Section 13501 of the Tax Cuts and Jobs Act created a withholding requirement on the transfer of non-publicly traded partnership interests[1] by amending §§864(c) and 1446 of the Internal Revenue Code.[2]   Section 864(c)(8) provides that gain or loss from the sale, exchange, or other disposition of a partnership interest by a nonresident alien or foreign corporation is effectively connected with …

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The IRS Announces New “Compliance Campaigns:” Unreported Virtual Currency, S-Corporation Compliance, and International Tax Enforcement Are Top Priorities

In International Tax, S Corporations, Tax Reform by Jason FreemanLeave a Comment

The IRS recently announced five new “compliance campaigns”—areas where it intends to focus additional resources and enforcement efforts.  It comes as no surprise that unreported virtual currency, S-corporation dividends, and international tax are at the core of its focus.  The five compliance campaigns are:   S-corporation Distributions Virtual Currency Restoration of AMT Credit Carryforwards Repatriation through Foreign Triangular Reorganizations Section …

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From Worldwide to Territorial, What Does It All Mean?

In International Tax, Tax Reform by Vu LeLeave a Comment

To understand the implications of the recent tax legislation and its reform of the international tax system, one first needs a grounding in basic U.S. international tax policies before delving into the major code changes. By understanding the origins of the system, we can see the policy behind the new provisions—and hopefully make them easier to digest.   Citizenship – …

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The Section 965 Transition Tax

In International Tax, Tax Reform by Jason FreemanLeave a Comment

The Tax Cuts and Jobs Act of 2017 enacted a number of important tax-law changes.  Few changes are more notable than those contained in the international tax provisions. Perhaps chief among the international tax changes was the Section 965 “transition” tax—a.k.a. the “deemed repatriation” tax. Section 965 generally requires that shareholders—as defined under section 951(b) of the I.R.C.—pay a “transition” tax …

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Tax Reform Under a Trump Administration

In Tax Reform by Jason Freeman3 Comments

The election of Donald J. Trump—an outcome that defied most conventional polling models—literally changed the prospect for major tax reform overnight.  With a republican-led congressional coalition at his back, President-elect Trump is likely to make good on many of his campaign promises when it comes to changing the tax code.  The reform to come could be sweeping; it could rewrite …