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Tax Report — Treasury Department Publishes Foreign Tax Credit Guidance, Includes GILTI Relief for R&D Expenses

USA - December 11 2019 The U.S. Treasury Department (“Treasury”) has released final regulations and proposed regulations (T.D. 9882) (the “Guidance”) providing rules related…

Sabrina Conyers, Chip Gray, Drew Hermiller, Mauricio D. Rivero

Proposed Regulations Provide Guidance on 20% Deduction for Qualified Business Income

USA - September 14 2018 The Department of Treasury issued in August proposed regulations (REG-107892-18) (the "Proposed Regulations") under Section 199A of the Internal…

Drew Hermiller, Maurice D. Holloway, Gene Crick Jr., Peter Schoemann

North Carolina Governor Signs Bill Addressing IRS Conformity and Other Significant Changes to North Carolina Tax Law

USA - July 6 2020 North Carolina Governor Roy Cooper signed into law H.B. 1080 (the “Bill”) on Tuesday, June 30, 2020. The Bill (i) decouples certain provisions of the…

Sabrina Conyers, Reed J. Hollander

Treasury Extends Deadline for Filing and Payment of 2019 Income Tax Returns

USA - March 30 2020 On March 20, 2020, the IRS issued Notice 2020-18 (the "Notice") which provides that the due date for making tax payments and for filing federal income…

Sabrina Conyers

IRS Says 'No Sale' on Transfer of LLC Interest From Subtrust to Deemed Owner Under Section 678

USA - June 5 2020 The Internal Revenue Service (“IRS”) recently issued a Private Letter Ruling (“PLR” or “Letter Ruling”) providing non-recognition treatment to the…

Blake G. Betheil, Maurice D. Holloway, Bobby Streisel