Jerald David August presented "Impact On: Closely Held Corporations" for the Impact of the New Tax Act Video Webcast
This presentation focused on the different treatments of closely held S corporations, C corporations, and their shareholders, under the new law. Topics included tax rates, conversions from C to S or S to C status, and the benefits of C corporations engaging in offshore business operations.
Jerald David August Outlines Impact of the "Tax Cuts and Jobs Act of 2017” at the ALI CLE Special Edition Webcast
The Tax Cuts and Jobs Act of 2017 will have a profound impact on tax planning for corporations, partnerships, and owners of U.S. owned businesses, as well as on foreign investors.
Jerald David August walked attendees of the ALI CLE Special Edition webcast through the details of the biggest U.S. tax legislation changes since 1986 and how those changes will significantly affect tax planning for clients and tax practices, as well as examining the key provisions of the tax law and their practical effects.
Repatriation of Foreign-Sourced Accumulated Earnings In Transitioning to a Participation Exemption System For Reporting Foreign Sourced Dividends Under The Tax Cuts and Jobs Act of 2017 *
On December 22, 2017, President Trump signed into law the Tax Cuts and Jobs Act (TCJA) of 2017, P.L. 115-97, which introduced a wholesale set of tax cuts and other reforms that affect substantially all U.S. taxpayers, both corporate and individual.
One of the highlights of the new law is the repatriation of foreign-sourced accumulated earnings and profits with respect to controlled foreign corporations (CFCs) as defined. Newly enacted section 965 imposes a transition tax on the accumulated (and untaxed) foreign earnings of foreign subsidiaries of US companies by constructive (mandatory) repatriation under section 951(a)(1). Foreign earnings held in the form of cash and cash equivalents are taxed at a 15.5% rate and the residual untaxed foreign earnings are taxed a rate of 8%. The “transition tax” may be paid in installments over an 8 year period.
Congress Gets Ready To Pass Historic "Tax Cuts And Jobs Act": A Look At The Complex New World Of The Qualified Business Deduction Rule Applicable To Partnerships, S Corporations And Sole Proprietorships
Adapted from an article to be published in the January, 2018 issue of the CPA Journal which is the official journal of the NY State Society of CPAs
By the time this article is published, we will know whether the new tax law was enacted by Congress and signed into law by President Trump. While the conference committee resolved the differences between the bills, and there indeed were many differences, at this point the conference agreement has selected the provisions going forward for the final vote of Congress. This article will focus on the new reforms to the tax rates applied to owners of unincorporated businesses with respect to qualified business income.
Jerald David August presented "Choice Of Entity For Owners Of A Closely Held Business With Tax Legislation On The Horizon" at the NYU 76th Institute on Federal Taxation
This presentation explored the various factors involved in advising clients on choice of entity decisions, including conversions of tax status and their tax impacts to the entity as well as the owners. The speakers compared the taxation and related tax attributes, including ownership attributes, attributable to C or regular corporations, S corporations, limited liability companies, limited partnerships, and general partners.
Jerald David August presented "U.S. Companies Making Outbound Investments, A Primer" at the NJ Bar Annual Tax Conference
Discussions included choice of entity decisions for U.S. persons engaging in business operations overseas, including the use of hybrid entities; nexus for foreign tax exposure including treaty provisions such as the permanent establishment rule, taxation of foreign source business income.
Chairman Brady Issues Official "Chairman’s Mark" Of The Tax Cuts And Jobs Act; House Ways And Means Committee Passed The Historic Tax Bill; And Senate GOP Tax Plan Released
House GOP Bill, H.R. 1 and Chairman’s Mark Amendments of November 9, 2017
On November 2, 2017, the Republican GOP released a comprehensive tax reform plan which introduced a set of individual and corporate tax reforms that have received much attention and criticism from both sides of the aisle. Summaries of the proposed legislation were described in this forum in “House Republicans Release Tax Reform Plan: Ways And Means Committee Chair Brady Suggests Flex Rate Package” posted on November 2, 2017, and “Republican GOP Tax Bill Introduces Major Reforms To The Taxation Of U.S. Corporations Engaged In Business Operations Overseas: Introduction Of The Participation Exemption” posted on November 3, 2017.
Republican GOP Tax Bill Introduces Major Reforms To The Taxation Of U.S. Corporations Engaged In Business Operations Overseas: Introduction Of The Participation Exemption
Overview of Need for Reform of Income Taxation of U.S. Corporations With Respect to Foreign Subsidiaries
As promised from various talks and presentations leading up to the introduction of H.R. 1, 115TH Cong., 1st Sess., the Tax Cuts and Jobs Act, as well as the recent Republican Unified Framework for Tax Reform, released September 27, 2017, the GOP Bill introduces major reforms to the international taxation of U.S. businesses, particularly U.S. corporations owning 10% or more of the stock of a foreign corporation. The changes are wide-sweeping and perhaps controversial and marks a paradigm shift in moving the taxation of U.S. corporations from a worldwide income system, with allowance for claiming deemed foreign tax credits on dividends received from such foreign corporations, to a territorial based, participation exemption system which is utilized by many foreign countries.