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Facebook's Proposed Section 230 Reforms Just Create New Problems #MFYV #Stephenkent #Bryanhyde #YoungVoices #TalkRadio #CurrentEvents --- Support this podcast: https://anchor.fm/fedbyravens/support
Facebook's Proposed Section 230 Reforms Just Create New Problems
This week on tax break, Steve and Loren are joined by Miller & Chevalier Tax Member Rocco Femia to discuss the recently proposed section 901 regulations' net gain requirement and new jurisdictional nexus standard, as well as the implications of these modifications. Thanks to our guest, Rocco Femia: https://www.millerchevalier.com/professional/rocco-v-femia ********* Questions? Contact us at podcasts@milchev.com. tax break is not intended and cannot be relied on as legal advice; the content only reflects the thoughts and opinions of its hosts. tax break is a podcast about tax law, brought to you by Miller & Chevalier and hosted by Steve Dixon and Loren Ponds. We'll provide you with perspective on select tax issues that will go deeper than what the tax press covers, but not so deep that you'll have to pull out your regulations or read treatises to follow along. The aim of tax break is to focus only on the tax law issues that we find interesting. Subscribe to tax break wherever you get your podcasts.
A review of the week's major US international tax-related news. In this edition: IRS proposed regulations on related-party hybrid transactions / hybrid entities sent to OMB for review – Proposed Section 163(j) regulations release imminent -- Final Section 965 transition tax regulations will include detailed ordering rules for determining E&P – IRS Commissioner says expect more informal guidance – US House tax leader eying 70-80 TCJA technical corrections for lame-duck legislation
A review of the week's major US international tax-related news. In this edition: Proposed Section 163(j) regulations sent to OMB Office of Information and Regulatory Affairs for final review – US Treasury Secretary issues statement opposing unilateral digital tax action – Senate tax leaders express opposition to EC Digital Services Tax proposal – US, Israel to establish task force to review existing tax treaty
A review of the week's major US international tax-related news. In this edition: US House tax leader releases Tax Reform 2.0 framework – OMB completes review of Proposed Section 965 transition regulations – OECD Secretary-General Report to G20 Finance Ministers and Central Bank Governors on BEPS, tax transparency released
Ron Aucutt, ACTEC Fellow from Tysons Corner, Virginia shared his perspective in October 2017 of Treasury's withdrawal of Section 2704 proposed regulations on valuation for transfer tax purposes. There are many valuable insights in this podcast as a revised set of regulations may yet be reproposed as some point by Treasury. Hear analysis of Big Six tax reform plan and effects on individuals and businesses. How will reform impact estate tax? Is timing realistic? Learn more... ACTEC Trust & Estate Talk offers professionals best practice advice, insights, and commentary on subjects that effect the profession and clients. ACTEC, a professional society of peer elected trust and estate lawyers, is passionate about estate and trust issues including elder law, estate planning, wealth planning, probate law, wills, living wills, power of attorney, guardianship, medical power of attorney, trusts, irrevocable trusts, special needs trusts, charitable trusts, trust funds, Rockefeller trusts, marital trusts, asset protection, family partnerships, estate taxes, gift taxes, tax legislation, tax law, and tax reform.
Congressional Republicans maintain opposition to Proposed Section 385 regulations -- IRS focusing on FATCA IGAs currently ‘in effect’ -- Obama Administration issues White Paper on EU State aid investigations – IRS final regulations issued on 2% tax on payments US government makes to foreign persons under certain contracts -- Treasury/IRS 2016-2017 Priority Guidance Plan contains several new international tax projects -- Lawsuit filed challenging anti-corporate inversion regulations -- OECD releases Discussion Draft on branch mismatch structures.
A review of the week's major US international tax-related news. In this edition: US Treasury and IRS issued 2016-2017 Priority Guidance plan – IRC Section 5000(c) final regulations released on 2-percent excise tax on US government payments to foreign persons -- Treasury official confirms Administration can address unintended consequences in Proposed Section 385 debt/equity regulations.
IRS and Treasury hold hearing on Proposed Section 385 debt/equity regulations – Senate Finance Committee Chairman’s corporate integration draft delayed -- IRS releases proposed Qualified Intermediary Agreement – IRC Section 385 cases in exam or litigation require coordination with IRS Associate Chief Counsel offices – IRS official lists international guidance slated for release before Obama Administration ends.
A review of the week's major US international tax-related news. In this edition: IRS holds hearing on Proposed Section 385 debt/equity regulations -- OECD to present criteria to identify uncooperative jurisdictions for tax transparency purposes – Multilateral instrument to be opened for signature by end of 2016 -- Additional OECD BEPS discussion drafts coming.
A review of the EPS 's major US international tax-related news. In this edition: Treasury officials brief members of Congress on Proposed Section 385 debt/equity regulations – IRS issues proposed Qualified Intermediary Agreement – OECD releases BEPS documents for public comment.
A review of the week's major US international tax-related news. In this edition: US releases final country-by-country (CbC) reporting regulations – House W&M Republicans request comment period extension for Proposed Section 385 debt/equity regulations; Treasury remains firm – House tax reform blueprint details to be filled in; House Democrats take aim – OECD releases more guidance on CbC reporting.
US releases final country-by-country (CbC) reporting regulations – House W&M Republicans request comment period extension for Proposed Section 385 debt/equity regulations; Treasury remains firm – House tax reform blueprint details to be filled in; House Democrats take aim – OECD releases more guidance on CbC reporting.
A review of the week's major US international tax-related news. In this edition: House Tax reform blueprint released -- Treasury and IRS set 14 July hearing on Proposed Section 385 debt/equity regulations – House Ways and Means Democrats comment on Proposed Section 385 regulations -- US, Luxembourg announce plans to modify triangular provision in tax treaty -- UK votes for Brexit; major consequences including in regard to taxation.
A review of the week's major US international tax-related news. In this edition: US Senate Finance Committee Democrats to target corporate inversions – US, EU continue dispute over EU state aid investigations – G-20 to promote tax certainty in wake of BEPS project -- Treasury ponders further changes to Proposed Section 385 debt/equity regulations – US Tax Court holds for taxpayer in nearly $1.36 billion transfer pricing case.
Tax reform and corporate integration dominate discussions in lead up to House tax reform blueprint – Comprehensive derivatives taxation draft released -- Congressional Republicans voice concern over Proposed Section 385 debt/equity regulations – US Treasury moving forward with optional CbC reporting in 2016 -- US proposed rules would require reporting by foreign-owned US disregarded entities -- ABA Tax Section meeting highlights proposed Section 385 and Section 305(c) regulations, US Model Treaty -- Six more countries sign tax cooperation agreement enabling automatic exchange of CbC reports.
A review of the week's major US international tax-related news. In this edition: A review of the week's major US international tax-related news. In this edition: Proposed Section 385 regulations a primary focus at recent ABA Section of Taxation meeting and PLI conference – Recent US model treaty also a topic at ABA meeting – House Ways and Means Tax Policy Subcommittee holds hearing to discuss ideas for broader tax reform – Senate Finance Committee Chairman Orrin Hatch to hold hearing to discuss corporate integration.