United States

The Tax Exchange - May 2017

2017 non-US repatriation opportunity

TAX BLOG

2017 non-US repatriation opportunity

Both the Trump administration’s tax proposal, as well as the House Republican Tax Blueprint, contain provisions which would tax unrepatriated earnings of foreign subsidiaries of U.S. multinational corporations.

  • May 31, 2017
Is state tax reform coming in waves?

TAX BLOG

Is state tax reform coming in waves?

Contending with several quarters of weak growth in overall state tax collections, between 25 and 40 states are facing revenue shortfalls. The budget season is heating up with a flurry of legislation proposed to close those budget gaps for the 2018 fiscal year.

  • May 30, 2017
Compensation planning for potential lower tax rates

TAX BLOG

Compensation planning for potential lower tax rates

Although the specific provisions and timing of tax reform remain uncertain, it seems likely that business tax rates will be lower in the future. Given this expectation, prudent planning for employers includes accelerating deductions into periods before the rates will drop, leading to a permanent tax savings from the rate differential.

  • May 26, 2017
Would you take a 13-1 long shot on the taxation of digital goods?

TAX BLOG

Would you take a 13-1 long shot on the taxation of digital goods?

A colt named Cloud Computing won the 142nd Preakness Stakes in Kentucky…at a 13-1 long shot. Unfortunately, the same risk/reward scenarios rarely exist when it comes to getting the taxation of digital goods and services right.

  • May 23, 2017
Can new debt vs. equity regs provide a good guide for S corporations?

TAX BLOG

Can new debt vs. equity regs provide a good guide for S corporations?

The IRS issued final and temporary regulations under Section 385 late last year describing characteristics that help determine whether an investment in a corporation is debt or equity. Although those regulations exempted S corporations from their application, they nonetheless provide guidance that can be useful to an S corporation.

  • May 18, 2017
IRS rules debt assumption avoids disguised sale treatment

TAX BLOG

IRS rules debt assumption avoids disguised sale treatment

In a recent private letter ruling, the IRS provided insight into how they view liability assumptions post issuance of the 2016 regulations.

  • May 16, 2017
Will congress pass mobile workforce legislation in 2017?

TAX BLOG

Will congress pass mobile workforce legislation in 2017?

Over the past decade, Congress has seen mobile workforce bills introduced in each session like clockwork. The intent of mobile workforce is to create a federal solution to the incongruity between the states’ income tax treatment of non-resident workers.

  • May 11, 2017
American Health Care Act approved by House of Representatives

TAX BLOG

American Health Care Act approved by House of Representatives

On May 4, 2017, the American Health Care Act (AHCA), which modifies the Affordable Care Act (ACA), was passed by the House of Representatives, but the bill still faces an uncertain future.

  • May 08, 2017
Connecticut sourcing guidance for companies in the finance industry

TAX BLOG

Connecticut sourcing guidance for companies in the finance industry

Historically, some entities in the financial service industry could not utilize Connecticut’s “financial service company” apportionment because the entity was either subject to the state income tax or did not meet the definition under the corporate business tax. With recent legislation and guidance from the Connecticut Department of Revenue Services, those rules no longer apply.

  • May 04, 2017