IRS Releases Preliminary Guidance On Certain Aspects Of The Amended Section 162(M) Provisions

The Internal Revenue Service has published Notice 2018-68 (the “Notice”), which provides long awaited, but limited guidance on the recent amendments to Section 162(m) of the Internal Revenue Code (“Section 162(m)”) by the Tax Cuts and Jobs Act of 2017 (the “TCJA”). Specifically, the Notice provides guidance regarding the identification of a “covered employee” and the grandfathering rules governing written and binding arrangements in effect on November 2, 2017. The Notice applies to any taxable year […]

By |September 5th, 2018|

Proposed Treasury Regulations Provide Details on Tax Reform’s Passthrough Deduction

The U.S. Department of Treasury and Internal Revenue Service released proposed regulations under the recently enacted section 199A of the Internal Revenue Code on August 8, 2018. Section 199A of last year’s tax reform was intended, through a deduction, to reduce the highest marginal tax rate on certain business income earned by passthrough entities (e.g., partnerships, S corporations, and sole proprietorships) from 39.6 percent to 29.6 percent. This deduction achieves greater parity with the […]

By |September 4th, 2018|

Outbound Acquisitions: Holding Companies Of Europe – A Guide For Tax Planning

When a U.S. company acquires foreign targets, the use of a holding company structure abroad may provide certain global tax benefits. The emphasis is on “global” because standard U.S. benefits such as deferral of income while funds remain offshore may not be available without further planning once a holding company realizes dividends and capital gains. In addition, the operative term is “may provide” because of steps that have been taken by the Organization for […]

By |August 31st, 2018|