Sean M. Webb
Sean is an associate in the Tax Department. He earned his J.D. from UCLA School of Law and his LL.M. from NYU School of Law, where he served as a graduate editor for the Tax Law Review.
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On October 2, 2019, the Internal Revenue Service (“IRS”) and the U.S. Department of the Treasury (the “Treasury”) issued Revenue Produce 2019-40 (the “Revenue Procedure”) and proposed regulations (the “Proposed Regulations”) that provide guidance on issues that have arisen as a result of the repeal of section 958(b)(4) by the tax reform act of 2017.[1] … Continue Reading
Recently, several of the presidential candidates and other prominent Democrats have suggested a number of different tax policy proposals, including wealth taxes, mark-to-market taxation, a VAT, additional taxes, increased income tax rates, and increased gift and estate taxes. This chart illustrates the various proposals, and this blog summarizes them.[1] This blog was updated on November … Continue Reading
Introduction On April 17, 2019, the Internal Revenue Service (the “IRS”) and the U.S. Department of the Treasury (the “Treasury”) issued a second set of proposed regulations (the “Proposed Regulations”) under section 1400Z-2 of the Internal Revenue Code (the “Code”) regarding the qualified opportunity zone program, which was enacted as part of the law commonly … Continue Reading
I. Introduction. On March 4, 2019, the Internal Revenue Service (the “IRS”) and the Department of the Treasury (the “Treasury”) released proposed regulations (the “Proposed Regulations”) regarding the deduction for “foreign-derived intangible income” (“FDII”) under section 250 of the Internal Revenue Code.[1] Section 250 was enacted in 2017 as part of the tax reform act.[2] … Continue Reading
On December 20, 2018, the Internal Revenue Service (the “IRS”) and the Department of the Treasury (the “Treasury”) released proposed “anti-hybrid” regulations (the “Proposed Regulations”) under sections 267A, 245A(e), and 1503(d) of the Internal Revenue Code.[1] Sections 267A and 245A(e) were enacted in 2017 as part of the tax reform act.[2] Very generally, these sections … Continue Reading
On December 13, 2018, the Internal Revenue Service (the “IRS”) and the Department of the Treasury (the “Treasury”) released proposed regulations (the “Proposed Regulations”) with respect to the “base erosion and anti-abuse tax” (the “BEAT”) under section 59A of the Internal Revenue Code.[1] The BEAT was enacted in 2017 as part of the tax reform … Continue Reading
On November 26, 2018, the Internal Revenue Service (the “IRS”) and the U.S. Department of the Treasury (the “Treasury”) issued proposed regulations (the “Proposed Regulations”) under section 163(j) of the Internal Revenue Code (the “Code”).[1] Section 163(j) limits the deductibility of net business interest expense to 30% of “adjusted taxable income” plus “floor plan financing … Continue Reading
IRS provides very modest relief from downward attribution resulting from the repeal of section 958(b)(4)
Democratic Tax Policy Proposals
By David S. Miller, Bowon Koh and Sean M. Webb on Posted in In the news, Tax Policy, Tax Reform
The Second Set of Proposed Opportunity Zone Regulations
By David S. Miller, Jean Bertrand, Sejin Park, Sean M. Webb, Amanda H. Nussbaum, Ira G. Bogner, Richard M. Corn, Martin T. Hamilton, Malcolm Hochenberg, Scott S. Jones, Mary B. Kuusisto, Arnold P. May, Jeremy Naylor, Alan Parnes, Jamiel E. Poindexter and Stuart Rosow on Posted in IRS, Opportunity Zones, Tax Cuts and Jobs Act, Tax Reform
Proposed FDII Regulations under Section 250
By David S. Miller, Sean M. Webb, Elizabeth Johnston Wytock, Amanda H. Nussbaum, Stuart Rosow, Richard M. Corn, Michael Fernhoff, Martin T. Hamilton, Malcolm Hochenberg, Scott S. Jones, Mary B. Kuusisto, Arnold P. May, Jeremy Naylor, Alan Parnes and Jamiel E. Poindexter on Posted in GILTI, International Taxation, IRS, Tax Cuts and Jobs Act, Tax Reform
Proposed Anti-Hybrid Regulations under Sections 267A, 245A, and 1503(d)
The Proposed BEAT Regulations
U.S. Tax Reform: IRS Proposes Interest Deduction Limitation Regulations
By Martin T. Hamilton, Annie Kim, David S. Miller, Amanda H. Nussbaum, Richard M. Corn, Sejin Park, Mani Kakkar and Sean M. Webb on Posted in Corporate tax, financial products, International Taxation, IRS, Partnership Taxation, Tax Cuts and Jobs Act, Tax Reform, U.S. Legislation
