18 Aug 2020
Treasury and IRS release long-awaited guidance on carried interest taxation
On July 31, 2020, the Treasury and IRS released proposed regulations regarding Sec. 1061’s carried interest rule, targeting incentive allocations made to fund managers.
7 Aug 2020
IRS issues guidance on GILTI high-tax exclusion
The Treasury and IRS have issued final regulations allowing taxpayers to exclude certain high-taxed income of a controlled foreign corporation from their global intangible low-taxed income (GILTI) computation on an elective basis.
5 Dec 2019
US gift tax – final regulations protect large gifts from future tax
The IRS has now confirmed that taxpayers benefiting from temporarily raised estate and gift tax exclusion amount will not be adversely impacted in future years.
11 Oct 2019
2019 Year-End Tips and Tax Planning Strategies for Individuals
As we head into the last quarter of the year there are several action items that US individual taxpayers may want to consider before year-end.
29 Sep 2019
The US States’ Evolving Responses to Tax Reform Present Opportunities and Challenges
The states’ responses to the sweeping changes under the Tax Cuts and Jobs Act (TCJA) are as varied as their own unique tax codes. Korwin Roskos of Andersen United States discusses the unique challenges and opportunities for business taxpayers.
25 Sep 2019
Alternative asset management – USA state and local tax update
On Thursday, September 26, Andersen United States will host a webcast on state and local tax and how recent updates have impacted the Alternative Investment industry.
4 Aug 2019
Non-US individuals, trusts and companies investing into the US
The tax treatment of US investments differs depending on whether the investor is an individual, company or trust. Investors need to understand the consequences of different investment structures so that they can plan their investment decisions for maximum tax efficiency.
18 Jul 2019
GILTI regs improve position for partnerships owning CFCs
Partners in private equity and domestic partnerships will benefit from these regulations if they do not own directly, indirectly or constructively 10% or more of the stock of a foreign corporation and thus will not be required to have a GILTI inclusion. The final regulations are applicable for tax years beginning after December 31, 2017.
4 Jul 2019
US estate taxes for non-Americans
Non-US individuals owning US assets could be exposed to US gift and estate tax on death or when the asset is gifted. Such individuals should seek advice to understand the level of exposure and whether any pre-emptive planning can be undertaken.
20 Jun 2019
IRS Issues Final and Proposed Regulations on GILTI
The IRS and Treasury have released final and proposed regulations regarding the new global intangible low-taxed income (GILTI) regime, applicable to US taxpayers with interests in foreign companies.
25 Jan 2019
Final Regulations on 20% Pass-Through Deduction Resolve Various Uncertainties
IRS and Treasury have released final regulations under Sec. 199A of the Internal Revenue Code (Code) regarding the 20% deduction for pass-through entities and certain individuals.
13 Dec 2018
Non-Americans investing into the US post-tax reform
The individual tax provisions of tax reform present opportunities for non-resident non-Americans investing into the US.