Ideas & Insights

New Jersey Division of Taxation rescinds unpopular GILTI and FDII allocation guidance issued in December; new guidance expected shortly.

The introduction of the services cost method concept to the Base Erosion Anti-Abuse Tax (BEAT) is a welcome benefit to some taxpayers.

Revenue Procedure 2019-33 provides procedures for taxpayers to make or revoke certain bonus depreciation elections.

Final regulations issued in late June 2019 on GILTI inclusion could have a considerably differently impact on PE and VC fund structures.

Budget bills address pass-through entity tax, sales tax base and nexus changes, tax credits and reporting obligations.

The California fiscal year 2020 budget addresses TCJA conformity and other new and amended state tax provisions.

For private equity firms, it is important to take a step back and evaluate what tax structure will be the most beneficial in the long-run.

Final regulations terminate Reg. Section 1.451-5, which previously allowed multiyear deferral of advance payments for goods and services.

Budget bills address pass-through entity tax, sales tax base and nexus changes, tax credits and reporting obligations.

The new pass-through entity level tax may benefit some individuals subject to the $10,000 SALT deduction limitation.

The 2019 legislature passed several tax changes, issued marketplace facilitator rules and provided additional credits and incentives.

Revisions to the U.S. income tax treaties with Switzerland, Luxembourg, Japan and Spain may pass the Senate after years of being stalled.

New York enacts legislation exempting 95% of GILTI and increases the sales component of the economic sales tax nexus threshold.

The proposed regulations clarify fixes addressing the “grain glitch” and specify information cooperatives must provide to their patrons.

The IRS FAQ states that 1231 gains invested in a QOF before the second set of proposed regulations can still be eligible for gain deferral.

The Senate recently passed the Taxpayer First Act after eliminating the controversial Free File Program from the bill.

Minnesota’s long-awaited conformity bill presents new challenges for individual and corporate taxpayers; remote seller provisions modified.

Withholding generally applies to transfers of partnership interests by foreign persons, regulations generally follow previous guidance.

Favorable estate planning rules in place to 2026 would be less so in 2021 under some Democrats’ proposals. Time to consider the what ifs?

9th Court of Appeals rejects common law “mailbox rule” in favor of section 7502 regulations detailing mailing requirements.