Section 965 Proposed Regulations Issued

On August 1, 2018, the Internal Revenue Service and the Department of the Treasury issued proposed regulations on the Section 965 transition tax, which was enacted under the Tax Cuts and Jobs Act. Section 965 levies a one-time transition tax on US shareholders on the accumulated offshore earnings in certain offshore companies and many taxpayers owe this tax with respect to their 2017 US tax year.

The proposed regulation package is significant and covers a […]

By |August 9th, 2018|

Tax Law Still Leaves Room For Companies To Write Off Settlement Agreements

In two recent Bloomberg Law articles, Kat Gregor comments on rules governing deductibility of payments enacted to governments as part of 2017 tax reform, including deporting requirements under section 6050X of the Code. The purpose of these new guidelines is to “boost transparency in corporate settlements and make it easier for the IRS to keep track of how much of a settlement payment a company is required to pay off.” Kat specifically notes that the Code’s […]

By |August 8th, 2018|

Australia Announces Changes To Tax Incentive For Research And Development (R&D)

Proposed changes to R&D tax incentives regime in Australia will reward R&D intensity. Companies operating in Australia can benefit significantly if they know how to tap into this opportunity.

An overhaul of the R&D tax incentive legislation in Australia has been proposed which will have the effect of rewarding businesses with greater R&D intensity i.e. higher R&D spend as a proportion of total spend. The changes, once implemented, will apply to financial years commencing on […]

By |August 8th, 2018|