ALI-CLE The Practical Tax Lawyer, Winter 2018 Edition Read More

The new tax law enacted in December swapped out a graduated corporate tax rate topping out at 35 percent with a flat 21 percent rate across the board. While this provision, combined with the elimination of the corporate alternative minimum tax (AMT), might seem to have simplified matters considerably, attorney Jerald David August, a tax partner at Kostelanetz & Fink, LLP, who spoke at the Foundation for Accounting Education’s conference “Impact of the New Tax Law: a Sid Kess Work… Read More

ALI-CLE Course Materials, January 18, 2018. VCZG0118 ALI-CLE 57…JOBS ACT OF 2017 IMPAC INTERNATIONAL TAX CHANGES UNDER TCJA Jerald David August Kostelanetz & Fink, LLP New York, New York Copyright (c) 2018 The American Law Institute (c) 2018 Jerald David August. All rights reserved. VCZG0118 ALI-CLE 57 2018 WL 551477… Read More

President Trump signed the Tax Cuts and Jobs Act (TCJA), H.R. 1, into I law on December 22, 2017. The law was passed by Congress two days earlier, on December 20, 2017. In general, the effective date of the TCJA is January 1, 2017. Many of the provisions of the TCJA will sunset on January 1, 2027, although some provisions are permanent. While the conference committee resolved the differences between the House and Senate bills- and there were indeed many differences-the Conference Committee selec… Read More

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.[1] Newly enacted section 965 imposes a transition tax on the accumulated (a… Read More

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.[1] Newly enacted section 965 imposes a transition tax on the accumulated (a… Read More

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 vo… Read More

From: ALI-The Practical Tax Lawyer (Winter 2017) The Bipartisan Budget Act of 2015 made fundamental changes to how the IRS will conduct audits of partnerships. This article by Jerald David August discusses the partnership audit rules prior to and as a result of TEFRA, drafting for three regimes involving IRS audits of partnerships, the partnership “pushout” election, election out of the Budget Act partnership audit rules, procedural issues/judicial review, the need for guidance in the form o… Read More