The Internal Revenue Service and the Treasury Department have issued details about the withholding on the transfer of non-publicly traded partnership interests by foreign persons under the Tax Cuts and Jobs Act, along with guidance on the “transition tax” on the untaxed earnings of overseas subsidiaries of U.S. companies.
This perspective has been written for CEOs at CPA firms doing $50 million to $100 million in annual revenue with quality profits per partner who want to make their firms bigger, better, stronger and more profitable.
At some point in my practice I had to ask a staff person if he would want to specialize in taxes. The first time occurred over 35 years ago when my main tax reviewer left for a position with another firm where he would be “more important than just a tax reviewer.”
The name that Republican tax writers gave to a new, multibillion-dollar business levy implies that it targets foreign earnings from “intangible” intellectual property—hitting tech firms and drugmakers like Apple Inc. and Pfizer Inc.