By Paul Tadros and Marc Schwartz After swimming (Treading water? Drowning?) in the new tax law for a few weeks, it’s healthy to pull back and look at some bigger picture items based on the changes to our and other countries’ laws. Here’s 3 items of interest (at least to us!). US as …
Musings on 3 Global Tax Issues Related to US Fiscal Reform Read More »
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 …
How the Tax Reform Limits Your Interest Deductions Read More »
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 …
International Tax Reform 4.0 – Transition Tax on Foreign Earnings – New Guidance Read More »
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