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Tax Liability Tax Cuts and Jobs Act Internal Revenue Code (IRC)

BakerHostetler

[Podcast] Implications of Supreme Court’s Tax Decision in Moore v. United States

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A team of BakerHostetler lawyers, led by Partners Andrew Grossman and Jeff Paravano, represented clients Charles and Kathleen Moore at the Supreme Court, arguing that realization is required for federal taxation of income...more

Holland & Knight LLP

Moore Thoughts: An Incremental Opinion from the U.S. Supreme Court

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The U.S. Supreme Court on June 20, 2024, ruled 7-2 that Section 965 of the Internal Revenue Code, as revised by the law known as the Tax Cuts and Jobs Act, is constitutional. The issue presented to the Court in Moore v....more

Eversheds Sutherland (US) LLP

Doing less with Moore: Supreme Court upholds section 965 transition tax in Moore v. United States

Almost exactly a year after it shook the tax world by granting certiorari, on June 20, 2024, the Supreme Court issued its opinion in Moore v. United States, No. 22-800. By a vote of 7-2, the Court upheld the constitutionality...more

Cadwalader, Wickersham & Taft LLP

Eager for Moore?

On December 5, the Supreme Court heard oral arguments on Moore v. United States, which is potentially the next landmark tax case on the meaning of income under the Sixteenth Amendment....more

Cooley LLP

Startups, Other R&D-Heavy Companies May Face Significantly Higher Tax Costs in 2022

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The Tax Cuts and Jobs Act was enacted more than five years ago, but certain changes under the legislation are only now coming into focus as taxpayers prepare their 2022 tax returns. In particular, there are significant...more

Freeman Law

Section 965 Tax Installment Payments Are Not Guaranteed

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The Section 965 transition tax. Taxpayers with international earnings are still grappling with their reporting and payment obligations under the “deemed repatriation” tax after its enactment by the Tax Cuts and Jobs Act of...more

Freeman Law

Tax Court in Brief | Rojas v. Commissioner | Deduction of Alimony and Child Support Under IRC Section 215

Freeman Law on

Tax Litigation: The Week of July 18th, 2022, through July 22nd, 2022 Pettennude v. Comm’r, T.C. Memo. 2022-79 | July 18, 2022 | Buch, J. | Dkt. No. 636-21L Gonzalez v. Comm’r, T.C. Summary Opinion 2022-13 | July 18, 2022 |...more

Freeman Law

Ninth Circuit Rejects Constitutional Challenges to Section 965 Tax

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In Moore v. United States, the U.S. Ninth Circuit Court of Appeals recently rejected arguments that the mandatory repatriation tax imposed under section 965 of the Internal Revenue Code violated the Constitution’s...more

Freeman Law

Final Regulations on Stock Owned by Domestic Partnerships under Subpart F

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On January 25, 2022, the Internal Revenue Services issued final regulations relating to the treatment of stock owned by domestic partnerships under certain provisions of subpart F of the Internal Revenue Code (“Subpart F”). ...more

ArentFox Schiff

One, Two, Three, Four . . . Can I Have a Little More? Another State Enacts SALT Cap Workaround

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While business owners wait to see whether Congress raises the U.S. long-term capital gains rate from 20 percent to 25 percent and enacts relief from the limitations on the deductibility of state and local taxes (SALT),...more

Freeman Law

The Section 965 Transition Tax And IRS Audits

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Section 965 audits are on the rise. Taxpayers under section 965 transition tax audits often face significant potential liability exposure. The IRS previously announced an active “campaign” specifically targeting unpaid...more

Freeman Law

Recent Tax Court Case and Theft-Loss Deductions

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A recent Tax Court case dealt with a familiar topic: Theft losses. I.R.C. section 165 has historically allowed taxpayers to deduct three types of losses: those incurred in a trade or business, those incurred in a transaction...more

Holland & Knight LLP

Tax Liability Issues to Consider for High-Net-Worth Couples in Divorce

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Divorce is not a topic most clients or tax advisors enjoy discussing. Nevertheless, it is important in today's day and age to advise clients, especially high-net-worth individuals with substantial assets located in the U.S....more

Foodman CPAs & Advisors

Are there conflicting signals from IRS as it relates to Section 965?

IRC Section 965 (Treatment of Deferred Foreign Income Upon Transition to Participation Exemption System of Taxation) was part of the TCJA enacted on December 22, 2017.  ...more

Jaburg Wilk

Divorce and Taxes

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When a couple is getting divorced both current and future tax obligations as well as tax basis are very important. There are four areas that we frequently advise our clients about. Originally published on ABC15 Sonoran...more

McDermott Will & Emery

Weekly IRS Roundup February 25 – March 1, 2019

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of February 25 – March 1, 2019. February 25, 2019: The IRS issued Revenue Ruling 2019-05,...more

Foodman CPAs & Advisors

IRS Guidance on Business Meals is Transitional

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The Tax Cut and Jobs Act (TCJA) amended Section 274 of the Internal Revenue Code (IRC) created a confusion for Taxpayers by disallowing a deduction for expenses with respect to “entertainment”, amusement, or recreation and...more

Holland & Knight LLP

U.S. Tax Reform: Impacts and Opportunities for Mexican Businesses, Part 1 - A General Overview on Issues That U.S. and Mexican...

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• The Tax Cuts and Jobs Act (Tax Act), signed into law on Dec. 22, 2017, made significant changes to the manner in which U.S. corporate and individual taxpayers are taxed on income from international operations. • The Tax...more

Foodman CPAs & Advisors

Swapping Virtual Currencies will trigger tax obligations under the Tax Cuts and Jobs Act

There are investors that have an interest in “exchanging or swapping” Virtual Currency (VC). Prior to the passage of the Tax Cut and Jobs Act (TCJA), VC investors could take the position that if they “exchanged or swapped”...more

Foodman CPAs & Advisors

Taxpayers may have to pay Section 965 Transition Tax when filing their 2017 Tax Returns

Section 965 of the Internal Revenue Code requires certain U.S. Shareholders to pay a transition tax on the untaxed foreign earnings of certain Specified Foreign Corporations as if those earnings had been repatriated to the...more

McDermott Will & Emery

Illinois Confirms Treatment of Deemed Repatriated Foreign Earnings Provisions

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On Wednesday, the Illinois Department of Revenue (Department) issued additional guidance concerning its treatment of the new deemed repatriated foreign earnings provisions found in Internal Revenue Code Section 965, enacted...more

Foster Garvey PC

Decoding the Tax Cuts and Jobs Act – Part VII: Family Matters and Major Events in the Lives of Individuals

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The Tax Cuts and Jobs Act (“TCJA”) creates the need for tax planning with respect to several major life-changing activities individuals may encounter, including marriage, divorce, home ownership, casualty losses, medical...more

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