Overview
JCT Releases TCJA Blue Book: The Joint Committee on Taxation (JCT) released its General Explanation of Public Law 115-97, the Tax Cuts and Jobs Act, commonly referred to as the “Blue Book.” For each provision of the Act, the Blue Book includes a description of prior law, an explanation of the provision, and the effective date prepared by the staff of the JCT in consultation with the staffs of the House Committee on Ways and Means, the Senate Committee on Finance, and the Treasury Department’s Office of Tax Policy. For reference, the joint explanatory statement previously released by the managers of the conference committee can be found here.
Treasury and IRS Submit Proposed Regulations on Dispositions of Partnership Interests: The Department of Treasury and the IRS submitted proposed regulations implementing section 864(c)(8), as enacted by the Tax Cuts and Jobs Act. Section 864(c)(8) generally overturned the Tax Court’s ruling in Grecian Magnesite Mining v. Comm’r, 149 T.C. No. 3 (2017) by providing that gain or loss of a nonresident alien individual or foreign corporation from the sale, exchange, or other disposition of a partnership interest is treated as effectively connected with the conduct of a trade or business within the United States to the extent that the transferor would have had effectively connected gain or loss if the partnership had sold all of its assets at fair market value as of the date of the sale or exchange. For prior coverage of the Tax Court’s ruling in Grecian Magnesite, click here.
Treasury and IRS Issue Proposed Anti-Hybrid Regulations: Treasury and the IRS issued proposed regulations implementing sections 245A(e) and 267A, enacted by the TCJA, regarding hybrid dividends and certain amounts paid or accrued in hybrid transactions or with hybrid entities.
European Commission Releases 2018 Tax Policy Survey: The European Commission released a report titled Tax Policies in the European Union, 2018 Survey. The survey examines how EU member states’ tax systems help to promote investment and employment, how they are working to reduce tax fraud, evasion and avoidance, and how tax systems help to address income inequalities and ensure social fairness.