Archive: tax reform

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U.S. Individual Shareholders of Controlled Foreign Corporations May Elect to Decrease Tax on GILTI

The Tax Cuts and Jobs Act (TCJA) enacted various U.S. international tax provisions. The new law includes the U.S. federal tax on global intangible low-taxed income referred to as GILTI. The GILTI rule applies to U.S. shareholders of controlled foreign corporations (CFCs). Effective on January 1, 2018, a U.S. shareholder of a CFC is required […]

U.S. Shareholders of Foreign Corporations and the Moving Target of Form 5471

The 2017 Tax Cuts and Jobs Act (TCJA) enacted significant changes to the U.S. international tax regime. U.S. shareholders are affected by the changes that impact the U.S. tax consequences of owning a foreign corporation. The TCJA revised the technical rules applicable to U.S. shareholders of controlled foreign corporations (CFCs). Along with issuing guidance on […]

Navigating S Corporation and Partnership Loss Planning Rules and Limitations

Prior to the enactment of the Tax Cuts and Jobs Act (TCJA), the largest tax overhaul in decades, individuals could freely deduct their flow-through business losses from their partnerships and S corporations against their wages and other investment income, subject to basis, at risk and passive activity limitations. As a result, a taxpayer with sufficient […]

Maryland Comptroller Clarifies GILTI Treatment

On April 17, 2019, the Comptroller of Maryland issued a Tax Alert to provide guidance to taxpayers on the state’s taxation of global intangible low-taxed income (GILTI), a new category of foreign earnings subject to federal income tax as a result of provision enacted by The Tax Cuts and Jobs Act (TCJA). The Tax Alert […]

Tax Reform 2.0 Passes the House

Making important headway on the proposals outlined in the legislative framework for tax reform 2.0, the U.S. House of Representatives approved the following three bills in September: R. 6760 – Protecting Family and Small Business Tax Cuts Act of 2018: The bill is intended to make permanent various individual tax provisions and Section 199A deduction […]

Tax Reform 2.0 Framework Focuses on Families and Entrepreneurs

As promised by House Ways and Means Committee Chairman Kevin Brady (R-TX) earlier this summer, a legislative framework for tax reform 2.0 was released on July 24th. The main focus of the framework, which contained numerous proposals, is assisting families and empowering entrepreneurs. A two-page outline includes the following proposals, which will be considered by […]

Kentucky Adopts Sweeping Tax Reform

On April 27, 2018, the Kentucky legislature voted to override Governor Matt Bevin’s veto of the comprehensive tax reform. Though many developments have emerged from the tax bill, the most significant include a flat five percent corporate tax rate, the adoption of single-sales factor apportionment formula and market-based sourcing, mandatory combined reporting for unitary groups, […]

Virginia Says “No” to Federal Tax Reform

On February 22nd and 23rd, 2018, the Virginia General Assembly enacted two pieces of emergency legislation, S230 and H154, that advances the Commonwealth’s conformity date with the Internal Revenue Code from December 31, 2016 to February 9, 2018. Although this results in Virginia conforming to the Disaster Tax Relief and Airport and Airway Extension Act […]

Estate and Gift Tax After the 2017 Tax Reform Act

Although the 2017 Tax Cuts and Jobs Act, or “Tax Act,” constituted the most sweeping change to the Internal Revenue Code in 30 years, very little changed regarding estate and gift taxes—except the estate and gift tax exemption. Whereas, prior to the Tax Act the post-2017 exemption was scheduled to be $5.6 million, the Tax […]

Key U.S. International Tax Provisions in the New Tax Legislation

The new U.S. Federal tax legislation includes some important revisions to the U.S. international tax rules. These rules are applicable to U.S. taxpayers with outbound cross-border activities in other countries. The following are some important highlights that could have an impact on the U.S. Federal tax obligations beginning as of January 1, 2018. 100% U.S. […]