The tax code limits some tax deductions to a fixed percentage of the taxpayer's taxable income. When multiple income-based limitations apply to a taxpayer at the same time, without specified ordering rules, the IRS has solved simultaneous equations to give proper effect to all the...

The tax concept of "earnings and profits" generally determines the amount of corporate distributions that is treated as taxable dividends for the shareholders. Earnings and profits are even more important for REITs, because of REITs' distribution requirements and the additional tax on...

Before the Tax Cuts and Jobs Act of 2017, U.S. federal income tax was generally imposed on the foreign income of a controlled foreign corporation (CFC) from certain passive sources or related party transactions (subpart F income). Each CFC had an incentive to avoid subpart F income, such as by...

The law formerly known as the Tax Cuts and Jobs Act of 2017 created a 20% deduction for income from certain passthrough businesses. The deduction, under new section 199A, is broadly available for lower income taxpayers, but that greater availability is gradually phased out for higher income...

The law formerly known as the Tax Cuts and Jobs Act of 2017 imposed a U.S. tax on the undistributed foreign earnings of certain foreign corporations. This tax on deemed repatriation income, under new section 965 of the Code, has some broad and surprising effects, particularly for individual...

The law formerly known as the Tax Cuts and Jobs Act of 2017 created qualified opportunity zones (QOZs), which are low-income census tracts in which certain investments by qualified opportunity funds (QOFs) are provided tax benefits. The investments generally cannot include any golf course,...

The law formerly known as the Tax Cuts and Jobs Act of 2017 made significant changes to tax deductions for individuals, which can adversely affect some married couples compared to their unmarried counterparts. The article discusses the state and local tax deduction (the same $10,000 annual limit...

The Tax Cuts and Jobs Act of 2017 created substantial new federal tax benefits for taxpayers with capital gain, if they make certain investments in so-called "qualified opportunity zones" (QO Zones). The QO Zone tax benefits generally include permanent tax exemption of up to 15% of the...

The headline international tax reform of the Tax Cuts and Jobs Act of 2017 was to switch the United States to a territorial taxation system. If a domestic corporation is a 10 percent or more shareholder of a foreign corporation, new section 245A generally provides the domestic corporation with a...