Articles in Tax

USTR Creates Web Portal for Section 301 Tariff Product Exclusion Requests

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he Section 301 tariff. USTR published its much-anticipated notice in the Federal Register.1 List 3 contains nearly 6,000 tariff classifications covering imported Chinese-origin goods valued at approximately USD 200 billion annually. The new web portal process is a different approach for submitting Section 301 product exclusion requests than regulations.gov used for filing exclusion requests covered by List 1 and List 2 of Read More

Beneficiary’s Residency Not Enough for State To Tax Trust, Supreme Court Rules

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The U.S. Supreme Court ruled unanimously today that a trust beneficiary’s residence in a state by itself doesn’t give the state the right to tax the trust. More specifically, the justices decided that North Carolina couldn’t tax trust income that (a) has not been distributed to the resident beneficiary, (b) the resident beneficiary has no right to demand and (c) Read More

New Opportunity Zones Guidance from IRS Clarifies Key Provisions of Program

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From its recent inception, the Qualified Opportunity Zone program has generated a lot of interest from potential investors, but many have waited until receiving further guidance from the Internal Revenue Service about how, exactly, a variety of aspects of the program will be handled. As of April 17, 2019, the waiting is over, with the second – and apparently final Read More

GDPR ONE YEAR ON – AN IRISH PERSPECTIVE

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25th May 2019 marked the first anniversary of [General Data Protection Regulation (EU) 2016/679] (the “GDPR”).   The GDPR governs the processing of personal data of EU data subjects.  It modernised and sought to harmonise the collection of previous data protection laws in Europe in a way which enhances a data subject’s rights and at the same time emphasises transparency, security Read More

Telecom Tax Ceilings in NYS – Inventory Filing Deadline Is April 30, 2019

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Further to our client alert from January, regarding the Court of Appeals’ decision in the T-Mobile case, it has come to our attention that the NYS Office of Real Property Tax Services (ORPTS) has begun to issue telecom ceiling determinations which include certain telecom assets (including fiber) that are now considered taxable real property as a result of that decision. ORPTS has also notified Read More

Section 301 Tariffs Might Extend Beyond China to the EU

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On April 12, 2019, the Office of the United States Trade Representative (USTR) published in the Federal Register a notice, Initiation of Investigation; Notice of Hearing and Request for Public Comments: Enforcement of U.S. WTO Rights in Large Civil Aircraft Dispute.1 The investigation could lead to the U.S. imposing tariffs on new, non-military helicopters, fuselages, undercarriages and civil aircraft parts from France, Germany, Read More

Opportunity Zone Update: New Proposed Regulations Released

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The United States Treasury Department released on Wednesday long-awaited new proposed regulations (“New Regulations”) to the Opportunity Zone Program, a tax incentive program created by the Tax Cuts and Jobs Act of 2017. The Opportunity Zone Program was designed to increase investment in certain economically distressed communities designated as “Opportunity Zones” by providing tax incentives to investors that reinvest gains Read More

Opportunity Zone Program Offers Attractive Tax Benefits for Long-Term Investors

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The Opportunity Zone program was created as a provision of the Tax Cuts and Jobs Act of December 2017. The program was developed with the intent to help encourage investment in economically distressed communities – called qualified opportunity zones (QOZs) – by allowing taxpayers to invest realized capital gains in qualified opportunity funds (QOFs). Investors in QOFs are granted both Read More

NAFTA May Be Replaced by USMCA: What Would That Mean for Your Taxes?

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On September 30, 2018, representatives from Canada, Mexico and the United States of America (the “U.S.”), announced that after thirteen months of intense negotiations, the three countries reached a preliminary agreement. This agreement revises the terms of the North American Free Trade Agreement (“the NAFTA”). The full text of the proposed agreement was published by the U.S. government on October Read More

Changes Overseas Investors in UK Property need to know about

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There are a number of changes that overseas investors need to know about if they hold UK property. The first relates to the introduction of capital gains tax (“CGT”).  Unlike many jurisdictions, foreign owners have not had to pay tax on UK property gains.  This is set to change from April next year.  From April CGT will apply to gains Read More