Section 245A

The Confused State of Tax Planning

We would like to thank Tax Analysts for publishing Schwartz International’s latest article written by our very own International Tax Nerds, Marc Schwartz and Paul Tadros. The article appears in the August 26th issue of Tax Notes Federal. In this article, Marc and Paul lament the complications that the Tax Cuts and Jobs Act has […]

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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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