Employee Benefits Blog

Posts tagged Tax Cuts & Jobs Act

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Treasury Department Releases Proposed Regulations Related to Section 965 Today

Proposed regulations related to Internal Revenue Code Section 965 were released today by the Treasury Department, providing additional guidance on the new repatriation tax on certain foreign earnings that was imposed by December 2017’s Tax Cuts and Jobs Act.

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New Guidance on Sec. 199A’s 20% flow-through deduction will be available any day

The new 20% deduction applicable to certain flow-through income is one of the most significant features of last December’s Tax Cuts and Jobs Act. As explained in a January BNN article, the text of this new rule, provided in new Internal Revenue Code Section 199A, is complex and often ambiguous. We have been awaiting promised guidance in the form of Treasury Regulations, and it now appears that the release of that guidance is imminent.

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Tax Reform Update

As most readers know, the passage of the Tax Cuts and Jobs Act (“TCJA”) last December rolled out some of the most significant tax law changes seen since Ronald Reagan was in office. It also introduced numerous questions regarding how to apply the new rules. Answers to those questions are expected primarily in the form of Treasury Regulations, which are IRS-written clarifications authorized (and often requested) by Congress. Regulations and other IRS pronouncements supplement the Internal Revenue Code (“IRC”), which houses the primary law itself.

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One-Time Deemed Dividend Repatriation Tax on Deferred Foreign Earnings

The recently passed tax act uses the mechanics of subpart F to impose a one-time “toll tax” on the undistributed, non-previously taxed, post -1986 foreign earnings and profits (E&P) of certain U.S.-owned corporations as part of the transition to a new partial territorial tax regime.

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New Opportunity Zones: Tax Deferral and Permanent Exclusion of Capital Gains

Significant - and little discussed –benefits of the Tax Cuts and Jobs Act

The Tax Cuts and Jobs Act of 2017 (TCJA) created three new tax incentives (summarized below) for investing in low-income communities. New Internal Revenue Code Sections 1400Z-1 and 1400Z-2 provide for the temporary deferral of inclusion in gross income for capital gains reinvested in a Qualified Opportunity Zone through a Qualified Opportunity Fund, and the permanent exclusion of certain capital gains resulting from the sale of an investment in a Qualified Opportunity Fund. These tax incentives are designed to encourage long-term investments in low-income communities, and complement the new markets tax credit.