Tax Talks

The Proskauer Tax Blog

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By: Proskauer Rose LLP

Blog Authors

Mani Kakkar
Richard M. Corn
Amy Drais
Ali Fawaz
Achille Gerbouin
Abraham Gutwein
Arnold P. May
Annie Kim
Amanda H. Nussbaum
Tony Oncidi
Alan Parnes
Andrea Rattner
Adam Scoll
Amy Zelcer
Brian Huber
Bowon Koh
Bali Kumar
Colleen Hart
Catherine Sear
Christine N. Sherman
Daniella Abel
Daniel Rothberg
David S. Miller
Emily Erstling
Elliot Katz
Elizabeth Johnston Wytock
Frank Zarb
Gabriella Ahdoot
Gregory Branagan
Gary Silber
Gary Tashjian
Hank Leibowitz
Ira G. Bogner
Justin Alex
Jamie Bowles
Janicelynn Asamoto Park
Jean Bertrand
James Huffman
Joseph Malca
Jeremy Naylor
Jon Oram
Joshua Miller
Jamiel E. Poindexter
Katrine Berger
Kimberly Ann Condoulis
Kate Napalkova
Kathleen R Semanski
Leslie Loffman
Louis Rambo
Lisa Vicens
Martin T. Hamilton
Michael Fernhoff
Mitchell Gaswirth
Malcolm Hochenberg
Mary B. Kuusisto
Marguerite Lombardo
Martine Seiden Agatston
Michael Sirkin
Rachel Hughes
Robert E. Gaut
Richard Miller
Rebecca Wallis
Steven Einhorn
Scott S. Jones
Sejin Park
Stephen Pevsner
Sara C. Richland
Stuart Rosow
Stephen Severo
Sean M. Webb
Timothy Donovan
Xiaoyang Ma
Jo Habenicht

Latest from Tax Talks

I.                   Introduction. On March 4, 2019, the Internal Revenue Service (the “IRS”) and the Department of the Treasury (the “Treasury”) released proposed regulations (the “Proposed Regulations”) regarding the deduction for “foreign-derived intangible income” (“FDII”) under section 250 of the Internal Revenue Code.[1] Section 250 was enacted in 2017 as part of the tax reform act.[2] Very generally, section 250 provides domestic corporations with a reduced effective 13.125% tax rate on FDII, which is…
Posted in Tax
On January 18, 2019, the U.S. Department of Treasury (“Treasury”) and the Internal Revenue Service (the “IRS”) released final regulations (the “Final Regulations”) regarding the “passthrough deduction” for qualified trade or business income under section 199A of the Internal Revenue Code.[1] The Final Regulations modify proposed regulations (the “Proposed Regulations”) that were released in August 2018. The Final Regulations apply to tax years ending after February 8, 2019, but taxpayers may rely on the…
Posted in Tax
On December 4, 2018, FinCEN issued Notice 2018-1, extending the filing deadline for the Report of Foreign Bank and Financial Accounts, FinCEN Form 114 (FBAR), for certain individuals with signature or other authority over (but no financial interest in) employer-owned foreign financial accounts to April 15, 2020. FinCEN has provided similar extensions over the previous six years.[1] This new extension applies to reporters with signatory authority during the 2018 calendar year and to…
Posted in Tax
On January 18, the Internal Revenue Service (“IRS”) and the U.S. Department of the Treasury issued final regulations (the “Final Regulations”) on the “pass through” deduction under section 199A[1] of the Internal Revenue Code (the “Code”). Very generally, section 199A provides individuals with a deduction of up to 20% of income from a domestic “trade or business” operated as a sole proprietorship or through a partnership, S corporation, trust, or estate. The Final Regulations…
Posted in Tax
On December 20, 2018, the Internal Revenue Service (the “IRS”) and the Department of the Treasury (the “Treasury”) released proposed “anti-hybrid” regulations (the “Proposed Regulations”) under sections 267A, 245A(e), and 1503(d) of the Internal Revenue Code.[1] Sections 267A and 245A(e) were enacted in 2017 as part of the tax reform act.[2] Very generally, these sections deny U.S. tax deductions associated with a financial instrument, transaction, or entity that is treated differently…
Posted in Tax
On December 13, 2018, the Internal Revenue Service (the “IRS”) and the Department of the Treasury (the “Treasury”) released proposed regulations (the “Proposed Regulations”) with respect to the “base erosion and anti-abuse tax” (the “BEAT”) under section 59A of the Internal Revenue Code.[1] The BEAT was enacted in 2017 as part of the tax reform act.[2] The BEAT is an additional tax that has the effect of a minimum tax on certain large…
Posted in Tax
From Proskauer’s Not For Profit / Exempt Organization Blog, a discussion of recent IRS guidance and New York State legislative relief on Internal Revenue Code 512(a)(7), added by the Tax Cuts and Jobs Act (“TCJA”)… https://nonprofitlaw.proskauer.com/2018/12/19/inclusion-of-qualified-transportation-fringe-benefits-in-ubti-guidance-relief-and-rumors-of-possible-repeal/…
Posted in Tax
IRS
On December 13, 2018, the Internal Revenue Service (the “IRS”) and the U.S. Department of the Treasury (the “Treasury”) issued proposed regulations (the “Proposed Regulations”) addressing various aspects of the withholding and information reporting regime commonly referred to as “FATCA”.[1] The Proposed Regulations provide significant relief from potential withholding and compliance burdens that U.S. and non-U.S. financial institutions would otherwise be subject to under FATCA. The preamble to the Proposed Regulations announces that taxpayers…