Tax Notes Talk

Eric Yauch discusses a provision of the Tax Cuts and Jobs Act that hasn't received a lot of attention: section 461(l), which caps excess business losses at $250,000 for individuals and $500,000 for joint filers.For more coverage in Tax Notes, see:New Loss Limitation Is on Government’s RadarNew Loss Limitation Hard to Calculate, Interpret With Other Rules

Jeremy Cape of Squire Patton Boggs discusses the tax issues arising from Brexit.For related coverage on Brexit, read these articles in Tax Notes:U.K. Tax is Lesser Concern in No-Deal BrexitU.K. Backs Customs Agents Facing Brexit Capacity ChallengeEU, U.K. Leaders Willing to Extend Brexit Transition PeriodBrexit Talks at Impasse Over Customs Backstop Proposal EU Proposes 'Least Intrusive' Customs, VAT Checks After BrexitThe U.K. Can’t Afford to Become a Tax Haven, Says Labour PoliticianEU Steps Up Complaint Against U.K. Over €3 Billion Customs FraudHMRC Warns of Customs and VAT Impact of No-Deal Brexit For more on the Jaffa Cakes and Pringles debate, see:Cake or Biscuit? Why Jaffa Cakes Excite PhilosophersThe Lord Justice Hath Ruled: Pringles Are Potato Chips

Andrew Breiner talks to practitioners about the various issues raised by state efforts to tax peer-to-peer car rentals. For related coverage, read these articles in Tax Notes:Illinois Governor Vetoes Car Sharing Bill, Proposes Own PlanStates Look to Tax the Car-Sharing IndustryAirbnb and the Sharing Economy

Andrew Velarde highlights the significant insights from the recent American Bar Association Section of Taxation meeting in Atlanta, where the Tax Cuts and Jobs Act was once again the main topic of discussion.For additional coverage of the ABA meeting, read these articles from Tax Notes:TCJA Shaping Global Discussion as Several Regs Near CompletionU.S. Antiabuse Rules, Imperfect International Tax Regs ComingTransition Tax Guidance Will Extend Transfer Agreement Due Date'Guideposts’ Revealed for R&D-intensive Business SpinoffsTreasury Clarifies 199A De Minimis Rules Have Cliff Rental Property Ownership Could Decide 199A EffectsTreasury: Qualified Improvement Property Needs Technical CorrectionBonus Depreciation Regs Unlikely to Be Finalized This Year

Amy Hamilton discusses the IRS's proposed regulations addressing workarounds to the cap on state and local tax deductions. For additional coverage of the SALT regs, read these articles from Tax Notes: California Governor Vetoes SALT Deduction Cap Workaround New York Coalition to Fight Federal SALT Regulations The Frivolous Challenge to the SALT Deduction Cap Practitioners Urge Caution in Passthrough SALT Cap Planning New Jersey Won't Scrap SALT Cap Workaround, Despite IRS Regs Treasury Receives More Than 1,500 Comments on Proposed SALT Regs Proposed Federal SALT Rules Would Close Private School Donation Strategy IRS Has Plan to Shut Down SALT Workarounds

Andrew Velarde and Alexander Lewis provide an in-depth look into the proposed regs on global intangible low-taxed income. Read Tax Notes’ latest coverage of the proposed GILTI regs: Treasury Assuages Some Concern Over GILTI Antiabuse Rule Breadth GILTI Regs Signal Business Interest Limits Might Apply Proposed GILTI Regs Could Result in Taxable Phantom Income Practitioners Bristle at GILTI Antiabuse Provision Practitioners Throw More Shade at GILTI Antiabuse Rules GILTI Regs Focus on Computations, Punt on FTC Issues

Stephanie Johnston, Robert Goulder, and David Stewart highlight the hot topics at the 72nd Congress of the International Fiscal Association recently held in Seoul. Check out these stories for coverage of the 2018 IFA Congress: EU Digital Taxation Plan Is ‘Not a Master Thesis’ OECD Makes Headway on Long-Term Answers to Tax Digital Economy OECD Finalizing Work to Enlist Digital Platforms to Collect VAT Judicial Oversight Important for GAAR Application, Judge Says Germany Wants Progress on BEPS, Minimum Effective Taxation EU Member States Remain Divided Over Digital Services Tax

Paige Jones talks to Jim Ford of Global Tax Management about how retailers are preparing to collect and remit sales and use taxes in the wake of the U.S. Supreme Court's decision in South Dakota v. Wayfair Inc.

David Stewart, Kristen Parillo, and Ryan Finley examine the Altera v. Commissioner case — everything leading up to the Ninth Circuit opinion, the withdrawal of the opinion by that court, and the status of the case now.

David Stewart and Eric Yauch delve into the details of the proposed regulations on the passthrough deduction under section 199A.