Proposed Treasury Regulations Provide Details on Tax Reform’s Passthrough Deduction

The U.S. Department of Treasury and Internal Revenue Service released proposed regulations under the recently enacted section 199A of the Internal Revenue Code on August 8, 2018. Section 199A of last year’s tax reform was intended, through a deduction, to reduce the highest marginal tax rate on certain business income earned by passthrough entities (e.g., partnerships, S corporations, and sole proprietorships) from 39.6 percent to 29.6 percent. This deduction achieves greater parity with the […]

By |September 4th, 2018|

Outbound Acquisitions: Holding Companies Of Europe – A Guide For Tax Planning

When a U.S. company acquires foreign targets, the use of a holding company structure abroad may provide certain global tax benefits. The emphasis is on “global” because standard U.S. benefits such as deferral of income while funds remain offshore may not be available without further planning once a holding company realizes dividends and capital gains. In addition, the operative term is “may provide” because of steps that have been taken by the Organization for […]

By |August 31st, 2018|

Proposed Bonus Depreciation Regulations Clarify Impact On Certain Transactions

The Internal Revenue Service (IRS) and Department of the Treasury recently proposed regulations that shed light on how the new, expanded bonus depreciation regime may work in the context of many common acquisitions involving corporations and partnerships. Pending the release of final regulations, a taxpayer may rely on the proposed rules with respect to property acquired and placed in service after September 27, 2017.1As such, these proposed regulations should be of interest to businesses […]

By |August 29th, 2018|