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The Tax Cuts and Jobs Act has created significant uncertainty regarding withholding on the disposition of interests in partnerships that have U.S. effectively connected income. It has been recommended that there be a delay in withholding.

This issue of Business Tax Quarterly discusses the looming deadline with the 2017 Tax Cuts and Jobs Act, Section 965, which introduced a one-time repatriation tax on specified foreign corporations’ previously untaxed earnings.

Spring 2018 Business Tax Quarterly - recommended business tax related reading on the one-time repatriation tax, the future of automation, artificial intelligence in business and society, blockchain technology, the US tax act, procurement and AI's implementation into the corporate environment.

On April 2, 2018, the IRS released additional guidance on IRC Sec. 965, the transition or repatriation tax. The absence of sufficient guidance from the IRS and many state tax authorities has made compliance with this tax provision rather challenging.

IRS has confirmed that fiscal year corporate taxpayers will apply a blended tax rate for fiscal years beginning before January 1, 2018 and ending after December 31, 2017 and not the flat 21% rate that generally applies under the new Tax Cuts.

We address two vital tax matters in this issue: On compliance, the new Section 965 deemed repatriation tax on certain foreign earnings and regarding process, the rise of automated technology and Artificial Intelligence.

It’s a great time to be running a middle-market firm in New York City. To gain insight into how leaders at middle-market firms can get in front of these and other developments, Crain’s Custom Studio spoke with a brain trust of experts.

The Tax Cuts and Jobs Act overhauls investing in foreign entities. In addition to expanding the definition of IP, the Act also implements the following base erosion provisions, effectively imposing a minimum tax on MNEs: GILTI, FDII, and the BEAT.

The Tax Cuts and Jobs Act was signed into law with most provisions effective after December 31, 2017. While many of the suggested provisions were omitted from the law, there are still provisions that will impact tax-exempt entities.

Under the subpart F rules, the earnings and profits of a controlled foreign corporation continue to be deferred until repatriated. The Tax Cuts and Jobs Act has modified subpart F. The following provides an overview of a number of those changes.

With new tax reform legislation affecting taxpayers across the board, what does this mean to the typical non-U.S. individual who was already new to the U.S. tax system as well as to U.S. citizens and Green Card holders living and working abroad?

On December 20, 2017, the U.S. Congress passed the Tax Cuts and Jobs Act (the "Act"). The Act makes major changes to many areas of the Internal Revenue Code (“the Code”). This article summarizes the changes to the foreign tax credit system.

Identity theft and fraud have now spread to the world of taxation and public accounting. Practitioners must take the approach that it is their obligation and duty to protect the public at-large. Let’s examine a few of the more common ID theft scams.

The participation exemption system will transition the U.S. into a quasi-territorial system. 100% of the foreign-source portion of dividends paid by a foreign corporation to a U.S. corporate would be exempt from U.S. taxation.

New York State's 2014 budget includes significant changes impacting corporate and individual tax laws. This article covers changes to corporate and personal income tax as well as tax credits and offsets, exemptions, procedure changes and estate tax information.

Treasury Department’s Financial Crimes Enforcement Network FinCEN released proposed changes to the regulations implementing the Bank Secrecy Act. FinCEN reserves the right to require FBAR reporting with respect to private equity funds, venture capital funds and hedge funds. People with authority over a foreign financial account may be required to file the FBAR. 

The IRS issued proposed regulations intended to address when certain management fee waiver arrangements would be treated as disguised payments under IRC Sec. 707(a)(2)(A) nearly a decade ago. With a newly reinvigorated IRS focusing its attention on high income and high wealth taxpayers, these regulations may finally see movement. This article offers insight into the potential changes – affected taxpayers should pay close attention to developments.

Equity interests and Section 83(b) election. This Alert addresses when and under what circumstances a section 83(b) election may be revoked. For more information on Section 83(b) Election, contact our employee benefit plan services group.

The NY Statutory Residence provision was intended to prevent tax evasion by New York residents. Info on NY statutory residence and the permanent place of abode provision. Gaied v New York State Tax Appeals and the details of the court case. State and local tax for New York.

New Jersey offers taxpayers opportunity to resolve outstanding tax liabilities for the tax periods 2005 - 2013. In exchange for resolving outstanding liabilities, New Jersey will waive most tax penalties and all collection costs and recovery fees for participating taxpayers.