Month: January 2018

How the Tax Reform Limits Your Interest Deductions

by Marc Schwartz   Prior law focused on and impacted members of international groups and some real estate investment trust (“REITs”). We’ve long had to consider whether business interest expense is deductible, but outside the REIT environment, IRC §163(j)’s earnings stripping rules generally applied in a global structure. These rules limited a corporation’s interest deductions …

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International Tax Reform 4.0 – Transition Tax on Foreign Earnings – New Guidance

In Notice 2018-07 (“Notice”), the IRS has moved quickly to provide preliminary guidance under Internal Revenue Code Section (“§”) 965, as amended by “An Act to provide for reconciliation pursuant to titles II and V of the concurrent resolution on the budget for fiscal year 2018,” P.L. 115-97, enacted on December 22, 2017. We’re impressed by …

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